Your Privacy Matters to 111ba — Here Is How We Protect It
At 111ba, we treat the personal information of every player with the highest level of care. This Privacy Policy explains in plain terms exactly what data we collect, why we collect it, how we use and protect it, and the rights you hold over your own information as a player on our Bangladesh platform.
This Privacy Policy ("Policy") explains how 111ba ("we", "us", "our") collects, uses, shares, stores, and protects the personal data of players and visitors ("you", "your") who use the 111ba website at 111ba.net and all associated services. By registering an account or using the platform, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should discontinue use of the platform and contact support to request account closure.
SSL Encryption
All data transmitted between your browser and the 111ba platform is protected by industry-standard SSL (Secure Socket Layer) encryption. Your personal details, payment information, and account credentials travel over an encrypted channel at all times.
No Data Selling
111ba does not sell, rent, or trade your personal information to any third party for their own marketing purposes. Your data exists to operate your account, improve platform services, and meet legal compliance obligations — nothing else.
Your Data, Your Rights
You have the right to access the personal data 111ba holds about you, to request corrections, and to request deletion in applicable circumstances. These rights are explained in full in the Your Privacy Rights section of this Policy.
Secure Storage
Player data is stored on secured servers with access limited strictly to authorised personnel. We apply role-based access controls, regular security audits, and data minimisation principles to reduce the risk of unauthorised access or disclosure.
Payment Data Handling
Payment method details (such as bKash, Nagad, and Rocket account numbers) are handled with strict confidentiality. 111ba does not store full card numbers on its own servers. Payment processing is managed by certified payment partners subject to their own security standards.
Transparent Communication
We will notify you of any material changes to this Privacy Policy by email or by a prominent notice on the platform before the change takes effect. We do not make silent changes to the way we handle your data without giving you reasonable notice.
Information We Collect
1.1 Information You Provide Directly
When you register an account, make a deposit, contact support, or otherwise interact with 111ba, you voluntarily provide personal information to us. The categories of information we collect directly from you include:
- Identity data: Full legal name, date of birth, and national identity card (NID) or passport number provided during registration or KYC verification.
- Contact data: Email address, mobile phone number, and residential address in Bangladesh (including city references such as Dhaka, Chittagong, Sylhet, Khulna , Rajshahi, Barisal, Rangpur, or Mymensingh).
- Account credentials: Username and hashed password chosen at registration. We do not store your password in plain text.
- Payment data: Mobile money account numbers (bKash, Nagad, Rocket, Upay), bank account details (Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank), and card details (Visa, Mastercard) used for deposits and withdrawals.
- Verification documents: Copies of identity documents, proof-of-address documents, and proof-of-payment-method submitted during KYC verification.
- Support communications: Records of Live Chat conversations, emails sent to [email protected], and any attachments or screenshots you share with our support team.
1.2 Information We Collect Automatically
When you access and use the 111ba platform, certain technical data is collected automatically by our systems. This includes:
- Device and browser data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
- Usage data: Pages visited, games played, betting history, session duration, clickstream data, and feature interactions within the platform.
- Transaction logs: Records of all deposits, withdrawals, bets placed, bonus claims, and account balance changes, including timestamps in Bangladesh Standard Time (BST, UTC+6).
- Location data: Approximate geographic location derived from your IP address, used for fraud prevention and regulatory compliance purposes.
1.3 Information from Third Parties
111ba may receive personal information about you from third-party sources in limited circumstances, including:
- Payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard) who confirm the status of your payment transactions.
- Identity verification and KYC service providers who assist us in confirming the authenticity of documents you submit.
- Fraud detection partners who provide risk signals associated with IP addresses, devices, or payment instruments.
- Our game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) who may share game-session data necessary to resolve disputes or technical issues.
KYC document submissions are handled confidentially and used solely for identity verification and fraud prevention. Documents are not used for any marketing purpose and are not shared with unrelated third parties.
111ba applies the principle of data minimisation: we collect only the personal information that is strictly necessary to operate your account, process your transactions, and meet our legal obligations. We do not collect data speculatively.
How We Use Your Information
2.1 Primary Purposes
The personal information 111ba collects is used for specific, lawful purposes directly connected to operating the platform and serving our players in Bangladesh. The primary purposes for which we use your data are set out in the table below.
| Purpose | Categories of Data Used | Legal Basis |
|---|---|---|
| Account registration and management | Identity data, contact data, account credentials | Contract performance |
| Processing deposits and withdrawals | Payment data, identity data, transaction logs | Contract performance |
| KYC and age verification | Identity data, verification documents | Legal obligation |
| Fraud prevention and security | Device data, IP address, usage data, transaction logs | Legitimate interest |
| Customer support | Identity data, contact data, support communications | Contract performance |
| Responsible gaming monitoring | Usage data, transaction logs, account settings | Legal obligation / Legitimate interest |
| Platform improvement and analytics | Usage data, device data (anonymised where possible) | Legitimate interest |
| Promotional communications (where opted in) | Contact data, usage data | Consent |
2.2 Marketing Communications
111ba may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, seasonal promotions (such as Eid specials, BPL season offers, or Pohela Boishakh rewards), and platform updates. We will only send you direct marketing communications where you have opted in to receive them during registration or through your account settings. You may withdraw your consent and opt out of marketing communications at any time by updating your notification preferences in your account settings or by contacting support at [email protected].
Withdrawing consent for marketing communications does not affect our ability to send you essential service communications, such as account security alerts, deposit confirmations, withdrawal notifications, and KYC request notices, which are sent on the basis of contract performance and are not optional.
2.3 Automated Decision-Making
111ba uses automated systems to monitor account activity for signs of fraud, money laundering, and responsible gaming concerns. These systems may result in automated actions such as account flags, temporary deposit restrictions, or automatic self-exclusion prompts. Where an automated decision has a significant effect on your account, you have the right to request human review of that decision by contacting our support team.
Marketing communications from 111ba are strictly opt-in. If you did not consent to receive promotional messages during registration, you will not receive them. You can manage your communication preferences at any time from within your account settings.
Our fraud detection and responsible gaming monitoring systems use automated analysis to protect both you and the integrity of the platform. If you believe an automated decision affecting your account was made in error, contact our support team to request a manual review.
Sharing and Disclosure of Data
3.1 Third-Party Service Providers
111ba shares personal data with a limited number of trusted third-party service providers who assist us in operating the platform. All such providers are contractually bound to handle your data only in accordance with our instructions and to maintain appropriate security standards. Categories of third-party providers who may receive your data include:
- Payment processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, BRAC Bank, City Bank — to facilitate deposits and withdrawals.
- Identity verification providers: Third-party KYC services used to verify the authenticity of identity documents and confirm player age.
- Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi — to deliver game content and resolve game-related disputes. These providers operate under their own privacy frameworks and are certified to applicable industry standards.
- Fraud prevention partners: Providers who supply risk scoring and device fingerprinting services to help us detect and prevent fraudulent activity.
- Analytics providers: Services used to analyse aggregated, anonymised platform usage data to improve the player experience.
- Customer support platforms: Live Chat software providers who host our support communication tools.
3.2 Legal and Regulatory Disclosure
111ba may be required to disclose your personal information to regulatory authorities, law enforcement agencies, or courts where we are legally compelled to do so. This includes disclosures made in connection with anti-money laundering (AML) obligations, counter-terrorist financing (CTF) requirements, or pursuant to a valid legal order. We will notify you of any such disclosure where we are legally permitted to do so.
3.3 Business Transfers
In the event that 111ba undergoes a business restructuring, merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity as part of that transaction. In such circumstances, we will ensure that the receiving party is bound by privacy obligations no less protective than those set out in this Policy, and we will notify affected players before their data is transferred to a new controller.
3.4 What We Do Not Do
For absolute clarity, 111ba does not:
- Sell your personal data to any third party for their own commercial use.
- Share your data with advertisers or ad networks for targeted advertising purposes.
- Disclose your data to other players or members of the public.
- Transfer your personal data to any recipient who is not bound by appropriate data protection obligations.
111ba only shares your data with third-party providers who are essential to delivering the platform's services. Every such provider is subject to a data processing agreement and is prohibited from using your information for any purpose beyond what 111ba has authorised.
Disclosures to regulatory or law enforcement authorities are made only when we are legally required to do so. 111ba does not voluntarily share player data with government bodies beyond the minimum required by applicable law.
Data Retention and Storage
5.1 Retention Periods
111ba retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following general retention periods apply:
- Active account data: Retained for the lifetime of your account plus a minimum of 5 years after account closure, in accordance with anti-money laundering record-keeping requirements.
- KYC and identity documents: Retained for a minimum of 5 years from the date of submission or the date of account closure, whichever is later.
- Transaction records: Retained for a minimum of 5 years from the date of the transaction.
- Support communications: Retained for 2 years from the date of the last interaction, unless the communication forms part of a dispute or legal record, in which case it is retained for the duration of the relevant proceedings plus 1 year.
- Analytical and usage data: Retained in anonymised form for up to 3 years for platform improvement purposes.
- Marketing consent records: Retained for 3 years from the date of consent, or until consent is withdrawn, whichever occurs first.
5.2 Data Deletion
When personal data is no longer required for any lawful purpose, 111ba securely deletes or anonymises it. Deletion is carried out in a manner that prevents recovery or reconstruction of the original data. Where anonymisation is used in place of deletion (for example, for aggregated analytics), the anonymised data can no longer be linked to any individual player.
5.3 Storage Location
111ba's player data is stored on secured servers. Data may be stored or processed in jurisdictions outside Bangladesh where our service providers operate, subject to appropriate data transfer safeguards. Where personal data is transferred internationally, we ensure that the recipient provides an adequate level of protection consistent with the standards set out in this Policy.
The 5-year minimum retention period for account, KYC, and transaction data reflects 111ba's obligations under applicable anti-money laundering regulations. This retention is mandatory and cannot be shortened even upon account closure or a deletion request.
Once the applicable retention period expires and no legal hold applies, your personal data is securely deleted. 111ba does not retain data beyond the periods necessary for operational and legal purposes.
Your Privacy Rights
6.1 Rights Available to You
As a player whose personal data is processed by 111ba, you hold the following privacy rights. To exercise any of these rights, contact our support team at [email protected] with the subject line "Privacy Rights Request" and include sufficient information to verify your identity.
- Right of access: You may request a copy of the personal data 111ba holds about you, together with information about how that data is used and shared. We will respond to access requests within 30 days.
- Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Certain corrections may require supporting documentation.
- Right to erasure: You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to overriding legal obligations — for example, we cannot delete transaction records within the mandatory 5-year retention window.
- Right to restrict processing: You may request that we pause the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing and we are considering that objection.
- Right to object: You have the right to object to processing of your personal data where it is based on legitimate interest, including for direct marketing purposes. We will cease direct marketing immediately upon receipt of an objection.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6.2 How to Exercise Your Rights
Submit your privacy rights request in writing to [email protected]. Please include your registered email address, the nature of your request, and a copy of a valid identity document so we can verify your identity before processing the request. 111ba will acknowledge all requests within 5 business days and aim to resolve them within 30 calendar days. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reason for it.
6.3 No Fee for Requests
111ba does not charge a fee for processing standard privacy rights requests. Where a request is manifestly unfounded, excessive, or repetitive, we reserve the right to charge a reasonable administrative fee or decline to act, providing written reasons for our decision.
To exercise any privacy right, email [email protected] with the subject line "Privacy Rights Request". Include your registered email address and a copy of your ID so we can verify your identity. We will acknowledge your request within 5 business days.
Some privacy rights — particularly the right to erasure — are subject to legal limitations. For example, transaction records and KYC documents must be retained for at least 5 years regardless of a deletion request. We will always explain clearly which data can and cannot be deleted and why.
Data Security Measures
7.1 Technical Safeguards
111ba implements a range of technical security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:
- SSL/TLS encryption for all data in transit between your browser and our servers.
- Encryption of sensitive data at rest, including stored payment references and identity document copies.
- Firewalls, intrusion detection systems, and regular vulnerability assessments of platform infrastructure.
- Two-factor authentication options for player accounts to reduce the risk of unauthorised login.
- Automated monitoring for anomalous login activity, including logins from new devices or unusual geographic locations.
7.2 Organisational Safeguards
In addition to technical controls, 111ba enforces strict organisational policies governing access to personal data:
- Access to player data is restricted on a need-to-know basis using role-based access controls. Support agents, finance staff, and compliance officers each have access only to the data categories required for their specific function.
- All staff with access to personal data undergo data protection training and are bound by confidentiality obligations.
- Third-party providers with access to player data are subject to contractual data security requirements and periodic review.
7.3 Data Breach Response
In the unlikely event of a data breach that poses a risk to your personal data, 111ba will take immediate steps to contain the breach, assess its scope and impact, and notify affected players without undue delay. Where the breach is likely to result in a high risk to your rights, we will contact you directly with details of the nature of the breach, the categories of data affected, and the steps you can take to protect yourself.
If you suspect that your account has been compromised, contact 111ba support immediately via Live Chat or at [email protected] so that your account can be secured and an investigation initiated.
No online platform can guarantee absolute security against all possible threats. However, 111ba invests continuously in its technical and organisational security measures to minimise risk and respond swiftly to any security incidents that may arise.
Your account security is a shared responsibility. Use a strong, unique password for your 111ba account, enable two-factor authentication where available, and never share your login credentials with anyone — including individuals claiming to be 111ba staff.
Changes to This Policy
8.1 How We Update This Policy
111ba reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, platform features, legal obligations, or regulatory guidance. When we make material changes to this Policy, we will notify you by:
- Sending a notification to the email address registered on your 111ba account.
- Posting a prominent notice on the platform for a reasonable period following the update.
- Updating the "Last Updated" date and version number at the top of this Policy.
Minor or administrative changes that do not materially affect the way we handle your personal data may be made without individual notification, though the "Last Updated" date will always be updated to reflect the current version.
8.2 Your Continued Use
Your continued use of the 111ba platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not agree with any material change to this Policy, you should discontinue use of the platform and contact support to request account closure in accordance with our Terms & Conditions.
8.3 Contact for Privacy Queries
If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which 111ba processes your personal data, please contact our support team in writing at [email protected] with the subject line "Privacy Enquiry". We will acknowledge your message within 5 business days and work to resolve your concern promptly and transparently.
111ba is committed to handling all privacy-related communications with care, discretion, and the full respect your personal information deserves.
You will receive an email notification at your registered address whenever this Privacy Policy is materially updated. We recommend keeping your registered email address current so that you do not miss important policy change notifications.
Privacy questions or complaints? Email [email protected] with the subject line "Privacy Enquiry". Our team is available 24/7 and will acknowledge your message within 5 business days.
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