Privacy Policy

This Privacy Policy ("Policy") describes how 111ck ("we", "us", "our") collects, uses, stores, shares, and protects personal information about individuals ("you", "your") who access or use the 111ck platform available at https://111ck.app, including all associated games, sports betting services, payment services, promotional features, and any other functionality provided through the Platform. This Policy forms part of the Terms and Conditions that govern your use of the Platform.

By registering an account, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and you consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform. You may withdraw your consent at any time by closing your account; please contact support via the email address in the footer to initiate account closure.

111ck is committed to protecting the privacy of its users. We collect only the personal data that is necessary to operate the Platform safely, comply with applicable regulatory obligations, process payments, prevent fraud, and deliver a high-quality experience to players in Bangladesh and wherever else our services are available. We do not sell your personal data to any third party, and we do not share it except in the limited circumstances described in this Policy.

111ck uses your personal data only for the purposes listed below. We do not use your data for automated decision-making that produces legal effects on you without human review. We do not use your data for profiling for advertising purposes outside the Platform.

111ck processes your personal data on the following legal bases: (a) Contractual necessity — processing required to perform our contract with you, namely to provide the Platform services you have registered for, process your payments, and manage your account; (b) Legal obligation — processing required to comply with applicable laws and regulatory requirements, including AML checks and age verification; (c) Legitimate interests — processing carried out to protect the Platform and its users from fraud, abuse, and security threats, where those interests are not overridden by your rights; (d) Consent — processing for promotional communications where you have given explicit consent, which you may withdraw at any time.

Where 111ck relies on legitimate interests as the legal basis for processing, we have assessed that those interests are balanced against your rights and do not override them. You have the right to object to processing carried out on this basis at any time by contacting support via the footer email address.

111ck does not sell your personal data. We share your data only in the following limited circumstances:

• Payment service providers (bKash, Nagad, Rocket, Upay) — to process your deposits and withdrawals. These providers receive only the transaction data necessary to complete the payment and are contractually bound to protect your information.
• Identity verification and KYC providers — third-party services used to verify the identity and age of players as required by our responsible gaming and anti-fraud obligations. These providers process identity data strictly for verification purposes.
• Game software providers (Pragmatic Play, Evolution Gaming, Spribe, and others) — to the extent technically required for game delivery. Game providers receive session tokens and bet data; they do not receive full identity profiles.
• Fraud detection and analytics service providers — who assist 111ck in identifying irregular patterns, suspicious transactions, and potential security threats. These providers process technical and usage data under strict data processing agreements.
• Competent authorities and law enforcement — where we are required by applicable law, court order, or lawful regulatory request to disclose personal data. We will inform you of such disclosures where we are legally permitted to do so.

All third parties with whom 111ck shares personal data are required to handle that data securely, to use it only for the purpose for which it was shared, and to comply with applicable data protection principles. 111ck remains responsible for ensuring that third-party processors maintain adequate data protection standards.

111ck uses cookies and similar technologies (such as local storage and session tokens) on the Platform. Cookies are small text files stored on your device that help the Platform function correctly, remember your session, and analyse how the Platform is used. We use the following categories of cookies: (a) Strictly necessary cookies — required for the Platform to operate, including session authentication tokens and security cookies. These cannot be disabled; (b) Functional cookies — remember your preferences such as language settings to improve your experience; (c) Analytics cookies — collect anonymised data about how players navigate the Platform to help us improve performance and layout.

111ck does not use advertising or tracking cookies to follow you across other websites. We do not engage in cross-site tracking or sell cookie-derived data to advertising networks. Most mobile browsers allow you to control cookies through browser settings; however, disabling strictly necessary cookies may prevent the Platform from functioning correctly.

111ck retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including for satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply: account data and identity documents are retained for the duration of your account plus a minimum of five years following account closure to satisfy AML and record-keeping obligations; transaction records are retained for a minimum of five years from the date of the transaction; usage and technical logs are retained for up to twelve months and then deleted or anonymised.

When personal data is no longer required, 111ck will securely delete or irreversibly anonymise it. Where data must be retained beyond the periods above to satisfy a legal hold or investigation, it will be held in restricted access storage and used only for the purpose of that legal requirement. You may request details of the retention period applicable to your specific data by contacting support.

111ck implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include 256-bit SSL/TLS encryption for all data in transit between your device and our servers, encrypted storage for sensitive personal data at rest, access controls limiting internal staff access to personal data on a strict need-to-know basis, regular security monitoring and anomaly detection on Platform infrastructure, and secure payment processing handled entirely by licensed payment partners including bKash and Nagad.

Despite these measures, no internet transmission or electronic storage system is completely secure. If you suspect that your 111ck account has been accessed without your authorisation, you should contact support immediately via the email address shown in the footer. You should also choose a strong, unique password for your account and never share your login credentials with any other person. 111ck support staff will never ask you for your account password.

As a user of the 111ck Platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact support via the email address shown in the footer. 111ck will respond to verified requests within a reasonable timeframe. We may need to verify your identity before processing your request.

The 111ck Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from any person under the age of 21. If we become aware that personal data has been collected from a person under 21, we will delete that data immediately and close the associated account. If you believe that a person under the age of 21 has registered an account or provided personal data to 111ck, please contact support immediately via the email address shown in the footer so that we can take prompt action.

The 111ck Platform integrates third-party game software from providers including Pragmatic Play, Evolution Gaming, Spribe, and Ezugi. These providers operate their own software environments under their own privacy and data practices. While 111ck takes reasonable steps to ensure our game partners maintain appropriate data standards, we are not responsible for the privacy practices of third-party providers once data is processed within their own systems. We recommend reviewing the privacy policies of any third-party service you interact with through the Platform.

111ck reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page. Where changes are significant and affect your rights as a data subject, we may also notify registered players by sending a message to the mobile number held on file. However, it remains your responsibility to review this Policy periodically to stay informed of how we handle your personal data.

Your continued use of the Platform after any update to this Policy constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must stop using the Platform and may request account closure by contacting support via the email address in the footer. Prior versions of this Policy are available on request.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 111ck handles your personal data, please contact our support team by email at the address shown in the footer of this page. When submitting a privacy-related request, please include your registered mobile number, a clear description of your request, and your preferred Bangladesh Standard Time (UTC+6) contact window. We aim to acknowledge all privacy requests promptly and to resolve them within a reasonable timeframe. Please do not include sensitive data such as your password or full financial account numbers in any support email.