Privacy Policy

This Privacy Policy ("Policy") is issued by x111me ("we", "us", "our", "the Platform") and applies to all personal data collected from users ("you", "your", "User") who access or use the x111me website at https://x111me.cam and all associated services, features and content (collectively, the "Services").

x111me is committed to protecting the privacy and personal data of its users in accordance with applicable data protection legislation. This Policy sets out, in clear and accessible English, what personal data we collect, why we collect it, how it is used, with whom it may be shared, how long it is retained and what rights you hold in relation to that data.

By registering an account on x111me or otherwise using the Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must not use the Services.

This Policy should be read alongside the x111me Terms & Conditions, which govern your use of the Platform more broadly.

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, email address, phone number, device identifiers, IP address and financial information.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer or deletion.
• "Data Controller" means x111me, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of x111me under contractual instruction.
• "KYC Data" means identity and age verification documents submitted as part of the Know Your Customer (KYC) process, including CNIC, passport, proof of address and liveness check data.
• "Cookies" means small text files placed on your device by the Platform to support functionality, analytics and personalisation.
• "PKR" means Pakistani Rupee, the currency of Pakistan, used for display and transactional reference purposes on the Platform.

x111me collects Personal Data through several channels and at various stages of your interaction with the Platform. The categories of data we may collect include:

We collect only the Personal Data that is necessary for the purposes described in this Policy. We do not collect sensitive categories of data (such as racial or ethnic origin, religious beliefs or health data) unless directly relevant to a responsible gambling assessment or AML obligation.

x111me processes Personal Data on the following legal bases, depending on the nature and purpose of the processing activity:

• Contractual Necessity: Processing required to perform the contract between x111me and the User — including account creation, transaction processing, game participation and support provision.
• Legal Obligation: Processing required to comply with applicable legal requirements — including KYC identity verification, anti-money laundering (AML) checks, age verification and fraud prevention obligations.
• Legitimate Interests: Processing carried out for the legitimate interests of x111me or third parties, where those interests are not overridden by your rights — including platform security, fraud detection, service improvement and responsible gambling monitoring.
• Consent: Processing based on your explicit consent — including the use of non-essential cookies and the receipt of optional marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

x111me uses your Personal Data for the following purposes:

• To create, manage and maintain your Account, including authentication and security controls.
• To process deposits, withdrawals and betting transactions — including displaying balances and transaction history in PKR where selected.
• To conduct KYC identity and age verification in compliance with applicable regulatory requirements.
• To detect, investigate and prevent fraud, money laundering, multi-accounting and other prohibited conduct as defined in the Terms & Conditions.
• To provide and improve customer support services, including responding to queries submitted via Live Chat, email at [email protected] and the Help Center.
• To administer and enforce responsible gambling tools — including deposit limits, session controls, cooling-off periods and self-exclusion — in accordance with our obligations and your requests.
• To communicate with you about account activity, security alerts, service updates and, where you have consented, promotional offers.
• To analyse Platform usage patterns in order to improve performance, usability and the overall user experience — particularly for mobile users in Pakistan.
• To comply with applicable legal, regulatory and reporting obligations.

x111me does not use your Personal Data to make automated decisions that produce significant legal or similarly significant effects without human oversight, except where required by applicable law (for example, automated fraud flagging subject to manual review).

x111me does not sell your Personal Data to third parties under any circumstances. We may share your Personal Data with the following categories of recipients where necessary and lawful:

• Payment Service Providers: To process deposit and withdrawal transactions, we share necessary transaction data with payment processors. Pakistani users should note that payment method references on x111me — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are contextual references only. Any data sharing with payment processors is strictly limited to what is necessary for transaction processing and is governed by those processors' own privacy terms. x111me does not imply any endorsement by these payment providers of the Platform or its services.
• KYC & Identity Verification Partners: Third-party identity verification services may process your KYC documents on our behalf to confirm identity, age and address. These processors operate under strict data processing agreements and are prohibited from using your data for their own purposes.
• Game and Platform Technology Providers: Software providers that supply casino games, sportsbook data feeds and Platform infrastructure may receive technical data necessary for the delivery of those services.
• Fraud Prevention and AML Services: Where required by applicable AML, counter-terrorism financing or fraud prevention obligations, Personal Data may be shared with specialist screening services or, where legally required, reported to relevant competent authorities.
• Legal and Regulatory Authorities: x111me will disclose Personal Data to regulatory bodies, law enforcement agencies or courts where required by applicable law or a valid legal order.
• Analytics Providers: Anonymised or aggregated usage data may be shared with analytics platforms to support Platform performance analysis. No directly identifiable Personal Data is shared for analytics purposes without appropriate safeguards.

All third-party Data Processors engaged by x111me are bound by data processing agreements that require them to process Personal Data only as instructed, to maintain appropriate security measures, and to delete or return data upon termination of the relationship.

x111me uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used include:

• Essential Cookies: Required for the Platform to function. These include session management cookies, authentication tokens and security cookies. Essential cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences — such as your preferred currency display (PKR), language settings and region — to provide a more personalised experience.
• Analytical Cookies: Used to collect anonymised information about how users interact with the Platform, including page visit frequency, session duration and navigation paths. This data is used to identify performance issues and improve usability.
• Marketing and Tracking Cookies: Used only where you have provided explicit consent, to deliver relevant content and measure campaign effectiveness. You may withdraw consent to non-essential cookies at any time via the cookie preference centre accessible from the Platform.

Most web browsers allow you to control cookie settings through the browser's preferences menu. Disabling certain cookies may affect your experience of the Platform, including your ability to remain logged in or to access certain features.

x111me retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, tax or accounting obligations. The following general retention principles apply:

• Account Data: Retained for the duration of the Account relationship and for a minimum period following Account closure as required by applicable AML and regulatory obligations (typically five years from the date of Account closure, subject to applicable law).
• KYC Documents: Retained for the period required by applicable identity verification and AML regulations, which may extend beyond Account closure.
• Transaction Records: Financial transaction data, including PKR deposit and withdrawal records, is retained for the period required by applicable tax, AML and financial reporting obligations.
• Support Communications: Retained for a reasonable period necessary to resolve disputes and support quality improvement, typically no longer than three years from the date of the interaction unless a longer period is required by law.
• Analytical and Technical Data: Typically retained in anonymised or aggregated form. Individually identifiable technical data (such as IP address logs) is retained for a shorter period commensurate with its security and fraud prevention purpose.

Upon expiry of applicable retention periods, Personal Data is securely deleted or anonymised in accordance with our data disposal procedures.

x111me implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, disclosure, alteration, loss or destruction. Our security measures include:

• HTTPS encryption across all Platform pages and data transmission channels.
• Passwords stored in hashed, salted form — plain-text passwords are never stored.
• Two-factor authentication options available to all Account holders.
• Restricted internal access to Personal Data on a need-to-know basis, with access logging and audit controls.
• Secure, encrypted channels for KYC document transmission and storage. Users must only submit sensitive documents through the Platform's official HTTPS verification portal — never via unsecured email, messaging applications or third-party channels.
• Regular review of security practices and third-party processor compliance.

While x111me takes data security seriously, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, x111me will notify you in accordance with applicable notification obligations.

x111me operates internationally, and your Personal Data may be transferred to and processed in countries outside the jurisdiction in which it was collected — including countries that may not offer the same level of data protection as your home country.

Where Personal Data is transferred internationally, x111me ensures that appropriate safeguards are in place, such as contractual clauses that impose equivalent data protection obligations on the receiving party, or transfers to jurisdictions recognised as providing adequate protection.

Pakistani users should be aware that Pakistani data protection law is still developing. While x111me endeavours to meet international data protection standards, users should review this Policy carefully to understand how their data may be handled across borders.

Subject to applicable law and certain limitations, you have the following rights in relation to the Personal Data x111me holds about you:

• Right of Access: You may request a copy of the Personal Data x111me holds about you and information about how it is being processed.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected without undue delay.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations (for example, AML retention requirements may prevent full deletion).
• Right to Restriction: You may request that processing of your Personal Data be restricted in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request your Personal Data in a structured, commonly used and machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests or for direct marketing purposes.
• 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 prior to withdrawal.

To exercise any of these rights, please contact x111me at [email protected]. We will respond to verifiable requests within a reasonable timeframe. We may need to verify your identity before processing your request.

x111me's Services are strictly intended for adults aged 18 and above — or the higher minimum age required by the operator's license jurisdiction. x111me does not knowingly collect Personal Data from individuals under the applicable minimum age. Age is verified as part of the KYC process.

If x111me becomes aware that Personal Data has been collected from an individual who did not meet the minimum age requirement at the time of collection, that data will be deleted and the associated Account will be closed. Any winnings obtained in breach of the age requirement will be forfeited in accordance with the Terms & Conditions.

If you believe a minor has registered on the Platform, please notify us immediately at [email protected].

x111me serves users across Pakistan, including in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. Pakistani data protection law is governed by a developing legislative framework. x111me endeavours to apply internationally recognised data protection standards to the handling of all user data, regardless of location.

Pakistani users should be aware of the following:

• x111me does not share your Personal Data with the Government of Pakistan, the PTA, the State Bank of Pakistan or any Pakistani financial institution unless required to do so by a valid legal obligation or court order.
• References to payment methods familiar in Pakistan — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are included for contextual reference only. These payment providers are not data processors for x111me and do not have access to your x111me Account data by virtue of their mention on this Platform.
• Pakistan has gambling restrictions, including the Prevention of Gambling Act, 1977. x111me does not claim to be licensed, endorsed or approved by any Pakistani authority. Nothing in this Policy constitutes legal advice. Pakistani users must satisfy themselves as to the legality of accessing the Services in their circumstances.

x111me reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. When material changes are made, we will provide notice through the Platform — for example, via a notification on next login or a prominent update banner.

The "Last reviewed" date at the top of this Policy indicates when it was most recently updated. Your continued use of the Services following the effective date of any revised Policy constitutes your acceptance of the updated terms. You are encouraged to review this Policy periodically.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a complaint about how x111me handles your Personal Data, please contact us through the following channels:

• Email: [email protected] — for data rights requests and privacy-related queries.
• Live Chat: Available through your Account dashboard in English. Urdu-language support is available through select channels.
• Help Center: Accessible from within the Platform, covering common privacy and account data questions.

x111me aims to respond to all formal data rights requests within 30 days of receipt, subject to identity verification and the complexity of the request. If your request is refused or only partially granted, we will explain the reason in writing.