Privacy Policy — How l1111 Collects, Uses, and Protects Your Personal Data

1. Data Controller

For the purposes of this Privacy Policy, the data controller responsible for your personal information is l1111, operating the platform at https://l1111.io ("l1111", "we", "us", "our"). As data controller, l1111 determines the purposes and means by which your personal data is processed. All data-related enquiries, access requests, and complaints should be directed to our support team at [email protected].

l1111 is committed to processing personal data in a manner that is lawful, fair, and transparent. This policy has been written to clearly inform you — our player — of every material aspect of how your data is handled from the moment you first visit our platform to the point at which your account is closed and your data is securely deleted.

2. Personal Data We Collect

l1111 collects personal data in several categories depending on the nature of your interaction with the platform. The categories of data we collect are set out in the table below:

l1111 does not collect or process any special-category sensitive data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification purposes, health data, or data concerning sexual orientation, except where explicitly required by law and with your express consent.

3. How We Collect Your Data

l1111 collects personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account profile.
• Automated collection: Technical data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you browse or use the l1111 platform.
• Third-party sources: Identity and fraud-check data received from our KYC verification partners, payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard), and anti-fraud screening services to verify your identity and protect the platform from abuse.
• Publicly available sources: In limited circumstances, l1111 may cross-reference data against publicly available registers or databases for fraud prevention and responsible gaming compliance purposes.

4. How We Use Your Personal Data

l1111 uses the personal data it collects for the following defined purposes:

• Account creation and management: To register your player account, verify your identity, and maintain accurate account records throughout the player relationship.
• Payment processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to confirm that payment methods belong to the registered account holder.
• Platform delivery: To provide access to all betting, live casino, slot, and crash game products available on l1111, and to personalise your platform experience based on your gaming preferences and history.
• Fraud prevention and security: To detect, investigate, and prevent fraud, money laundering, multi-accounting, bonus abuse, and other prohibited conduct. This includes automated risk-scoring of transactions and gaming patterns.
• Responsible gaming compliance: To monitor gaming activity for indicators of problem gambling behaviour, apply account restrictions where required, process self-exclusion requests, and enforce deposit and session limits set by the player.
• Customer support: To respond to your enquiries, process complaints, and communicate account-related information via live chat and email.
• Legal and regulatory compliance: To fulfil obligations under applicable laws and regulations, including anti-money laundering (AML), know-your-customer (KYC), and data protection requirements.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may opt out at any time.
• Platform analytics and improvement: To analyse aggregated usage data, identify technical issues, and improve the performance, design, and content of the l1111 platform.

5. Legal Basis for Processing

l1111 processes your personal data only where a valid legal basis exists. The legal bases we rely on are:

• Contractual necessity: Processing required to enter into or perform the contract between you and l1111 — including account registration, identity verification, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, and financial record-keeping obligations.
• Legitimate interests: Processing carried out in pursuit of l1111's legitimate business interests — such as fraud prevention, platform security, responsible gaming monitoring, and analytics — where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for optional marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

l1111 does not sell, rent, or trade your personal data. We share data only with the following categories of trusted third parties, strictly for the purposes described in this policy:

• Payment service providers: bKash, Nagad, Rocket, Upay, and card processors (Visa, Mastercard acquiring banks) — to process deposits and withdrawals on your behalf.
• Identity verification partners: Third-party KYC and AML screening providers used to verify your identity documents and screen against sanctions and watchlists.
• Fraud prevention services: Specialist anti-fraud platforms that analyse transaction and behavioural data to detect and prevent fraudulent activity.
• Game providers: Where technically necessary, anonymised or pseudonymised session data may be shared with game providers (such as Evolution Gaming, Pragmatic Play, Ezugi, Spribe, NetEnt, Microgaming) to facilitate gameplay and resolve disputes.
• IT infrastructure and cloud providers: Hosting, data storage, and technical infrastructure partners who process data on l1111's behalf under strict data processing agreements.
• Legal and regulatory authorities: Where required by law, court order, or the legitimate request of a competent regulatory or law enforcement authority.

All third-party data processors engaged by l1111 are bound by contractual obligations that require them to process data only in accordance with l1111's instructions and to maintain appropriate technical and organisational security measures.

7. International Data Transfers

The l1111 platform serves players located in Bangladesh and processes data in connection with that service. Some of l1111's third-party service providers may be located in jurisdictions outside Bangladesh. Where personal data is transferred internationally, l1111 ensures that appropriate safeguards are in place — including standard contractual clauses, data processing agreements, or transfers to jurisdictions that provide an adequate level of data protection — before any such transfer takes place.

If you would like more information about the international transfer mechanisms l1111 relies upon, please contact us at [email protected].

8. Data Retention

l1111 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, and in any event for no longer than required by applicable legal and regulatory obligations. The following general retention periods apply:

When the applicable retention period expires, l1111 will securely delete or irreversibly anonymise the data so that it can no longer be associated with any identifiable individual.

9. Security Measures

l1111 implements a comprehensive set of technical and organisational security measures designed 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 the l1111 platform.
• Encryption of sensitive data at rest, including stored financial and identity records.
• Role-based access controls that restrict access to personal data to only those l1111 employees and contractors who require it to carry out their specific job functions.
• Regular internal and third-party security audits and penetration testing of the l1111 platform infrastructure.
• Automated fraud detection and anomaly-monitoring systems that flag unusual account activity in real time.
• Mandatory two-factor authentication for internal l1111 administrative access to player data systems.
• Incident response procedures that ensure data breaches are identified, contained, and reported to affected individuals and relevant authorities within legally required timeframes.

While l1111 takes all reasonable steps to protect your data, no transmission over the internet or electronic storage system is 100% secure. Players are encouraged to use a strong, unique password for their l1111 account and to enable two-step verification from within the account security settings.

10. Cookies & Tracking Technologies

l1111 uses cookies and similar technologies (web beacons, pixel tags, local storage) on its platform. Cookies are small text files stored on your device that allow the platform to recognise you across pages and sessions. The categories of cookies l1111 uses are as follows:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in, security cookies that prevent cross-site request forgery, and load-balancing cookies. These cannot be disabled without rendering the platform inoperable.
• Functional cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming limits, so you do not need to re-enter them on each visit.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the l1111 platform — such as which pages are visited most frequently, how long sessions last, and where users encounter errors. This data helps l1111 improve platform performance and content.
• Security and fraud-prevention cookies: Used in conjunction with l1111's fraud detection systems to identify suspicious behavioural patterns, detect bot activity, and flag anomalous login attempts.

11. Your Data Rights

As an l1111 player, you hold the following rights in relation to your personal data. To exercise any of these rights, contact [email protected] with a clear description of your request. l1111 will respond within 30 days of receipt.

• Right of access: You have the right to request a copy of all personal data l1111 holds about you, along with information about how it is being used.
• Right to rectification: You have the right to request correction of any personal data that is inaccurate or incomplete. You may also update most account details directly within your l1111 account profile.
• Right to erasure ("right to be forgotten"): You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where consent has been withdrawn, or where processing is unlawful. This right is subject to l1111's legal data retention obligations.
• Right to restriction of processing: You have the right to request that l1111 temporarily suspend the processing of your data in certain circumstances — for example, while the accuracy of data is under dispute.
• Right to data portability: You have the right to receive a copy of the personal data you provided to l1111 in a structured, commonly used, machine-readable format, and to transmit that data to another data controller.
• Right to object: You have the right to object to l1111 processing your data on the basis of legitimate interests, including for direct marketing purposes. Where you object to marketing, l1111 will cease processing your data for that purpose immediately.
• Right to withdraw consent: Where l1111's processing is based on consent (e.g., for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

12. Minors & Age Verification Policy

The l1111 platform is strictly intended for adults. Players must be at least 21 years of age to register an account and use any service on the platform. l1111 takes the protection of minors extremely seriously and applies the following age-related safeguards:

• All players are required to confirm their date of birth during registration and are subject to mandatory KYC age verification before any withdrawal is processed.
• l1111 may request documentary proof of age (government-issued ID, passport, or National ID card) at any point during the player relationship.
• Accounts where the player is found to be under 21 years of age will be immediately closed, all bets voided, and any deposited funds returned to the original payment source.
• l1111 does not knowingly collect personal data from individuals under the age of 21. If we become aware that such data has been collected, it will be deleted immediately.

If you are a parent or guardian and believe that a minor in your care has registered or attempted to register an account on l1111, please contact us immediately at [email protected]. We will investigate and take appropriate action without delay.

13. Marketing Communications

l1111 may send you promotional emails, bonus notifications, and platform update messages where you have opted in to receive such communications during account registration or via your account communication preferences settings. All marketing communications from l1111 will:

• Clearly identify l1111 as the sender.
• Include a clear and functional unsubscribe mechanism in every email.
• Not be sent to any player who has opted out, self-excluded, or whose account has been closed.
• Comply with responsible gaming principles — l1111 will not send promotional material to players who have applied deposit limits, cooling-off periods, or self-exclusion restrictions to their accounts.

To opt out of marketing communications at any time, click the unsubscribe link in any l1111 promotional email, update your communication preferences in your account settings, or contact support at [email protected]. Opt-out requests are processed within 48 hours.

14. Third-Party Links

The l1111 platform may contain references to third-party services such as payment providers (bKash, Nagad, Rocket, Upay) and game providers (Evolution Gaming, Pragmatic Play, Ezugi, Spribe, NetEnt, Microgaming). These third-party services operate under their own independent privacy policies. l1111 is not responsible for the privacy practices of any third-party service and encourages players to review the privacy policies of any third-party platforms they interact with.

15. Changes to This Privacy Policy

l1111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, l1111 will notify registered players by email and by posting a prominent notice on the platform homepage at least 14 days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how l1111 protects your personal data. Your continued use of the l1111 platform after the effective date of any updated policy constitutes your acceptance of the revised terms.

If you disagree with any material changes to this Privacy Policy, you have the right to close your account and request deletion of your personal data, subject to l1111's mandatory legal retention obligations as described in Section 8.

16. Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way l1111 handles your personal data, please contact our Data Protection team using the details below:

l1111 takes all privacy complaints seriously. Upon receipt of a complaint, we will:

• Acknowledge your complaint within 2 business days.
• Investigate the matter thoroughly and in good faith.
• Provide a full written response within 30 days, or inform you if additional time is required.
• Take corrective action where the complaint is found to be valid.