bt111 Privacy Policy —
How We Handle Your Personal Data

bt111 ("bt111", "we", "us", or "our") is committed to protecting the personal data of every individual who interacts with the bt111 platform at bt111.one, including all associated subdomains, mobile applications, and related gaming and betting services. This Privacy Policy describes our practices with respect to the collection, use, storage, disclosure, and protection of personal data obtained in connection with your use of the bt111 platform.

This Privacy Policy applies to all bt111 members, registered account holders, and visitors to the bt111 website, regardless of their geographic location, including members based in Pakistan and across the wider South Asian region. By registering a bt111 account, depositing funds, or otherwise accessing any component of the bt111 platform, you confirm that you have read and understood this Privacy Policy and consent to the data processing practices described herein.

This Privacy Policy should be read in conjunction with the bt111 Terms and Conditions, which govern your overall use of the bt111 platform, and the bt111 Responsible Gaming Policy. In the event of any conflict between this Privacy Policy and any other bt111 document, the Terms and Conditions shall prevail unless this Privacy Policy expressly states otherwise.

For the purposes of applicable data protection law, bt111 acts as the data controller in respect of the personal data it collects and processes from members and platform visitors. As data controller, bt111 determines the purposes for which personal data is processed and the means by which such processing is carried out.

bt111 operates under an international gaming licence and maintains data processing standards aligned with internationally recognised privacy frameworks. Notwithstanding the international nature of bt111's operations, our data handling practices are designed to uphold the privacy rights of all members, with specific attention to the needs of our Pakistani member base.

Questions relating to this Privacy Policy or bt111's data processing activities may be directed to the bt111 data protection team via the contact details provided in Section 15 of this policy.

bt111 collects personal data across several categories depending on the nature of your interaction with the platform. The following table summarises the principal categories of personal data bt111 collects and processes:

bt111 collects personal data through the following primary mechanisms:

4.1 Direct Collection

bt111 collects personal data directly from you when you register a bt111 account, complete KYC verification, make a deposit or withdrawal request, contact bt111 customer support via live chat or email, participate in a promotion or tournament, complete a player preference survey, or update your account settings. All information you provide directly to bt111 is collected with your knowledge.

4.2 Automated Collection

When you access the bt111 platform, bt111 automatically collects technical and usage data through server logs, cookies, local storage, and similar tracking technologies. This automated collection occurs each time you visit the bt111 website or use the bt111 mobile application and does not require your active input. For full details of bt111's use of cookies and tracking technologies, please refer to Section 8 of this policy.

4.3 Third-Party Sources

bt111 may receive personal data about you from third-party sources including payment processors (such as JazzCash, EasyPaisa, and Pakistani banking partners), identity verification service providers engaged by bt111 for KYC purposes, fraud detection and anti-money laundering (AML) screening services, and analytics and technology partners. Any data received from third-party sources is handled in accordance with this Privacy Policy.

bt111 processes personal data on the following legal bases, in accordance with internationally recognised data protection principles:

• Contractual Necessity: Processing required to perform the bt111 member agreement, including account creation, processing deposits and withdrawals, settling bets, and providing customer support;
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, responsible gaming regulations, and gaming licence conditions;
• Legitimate Interests: Processing carried out in bt111's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, business analytics, and improving the quality of bt111 services, where such interests are not overridden by your fundamental privacy rights;
• Consent: Processing based on your explicit consent, including for marketing communications, optional preference personalisation, and the processing of any special category data required for regulatory purposes. You may withdraw consent at any time without affecting the lawfulness of prior processing.

bt111 uses the personal data it collects for the following purposes:

6.1 Account Management and Service Delivery

To create and maintain your bt111 account; to verify your identity and age at registration and at subsequent verification milestones; to process deposits, withdrawal requests, and PKR wallet transactions via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other approved payment methods; to settle sports bets, casino wagers, and arcade game outcomes; and to provide access to all bt111 platform features including cricket betting markets, PSL odds, live casino tables, slot games, and fish shooting arcade titles.

6.2 Regulatory Compliance and AML

To satisfy bt111's obligations under its international gaming licence, including KYC verification, AML transaction monitoring, responsible gaming record-keeping, and the reporting of suspicious transactions to relevant authorities as required by law.

6.3 Responsible Gaming

To monitor member activity for signs of problem gambling behaviour; to enforce self-imposed deposit limits, session time limits, and self-exclusion requests; to identify members who may benefit from responsible gaming resources or intervention; and to maintain records required under bt111's responsible gaming policy.

6.4 Security and Fraud Prevention

To detect, investigate, and prevent fraudulent activity, duplicate account registration, bonus abuse, match fixing, money laundering, and other prohibited activities as defined in the bt111 Terms and Conditions; and to maintain the security and integrity of the bt111 platform.

6.5 Communications and Support

To respond to customer support enquiries and complaints; to send transactional communications relating to your account including deposit confirmations, withdrawal notifications, KYC status updates, and security alerts; and to send marketing communications regarding bt111 promotions, new game launches, PSL special offers, and bonus opportunities where you have opted in to receive such communications.

6.6 Platform Improvement and Analytics

To analyse usage patterns and gameplay data in aggregate to improve the design, functionality, and content of the bt111 platform; to develop new product features and game categories based on member preferences; and to measure the effectiveness of bt111 promotional campaigns and marketing activities.

bt111 does not sell, rent, or trade your personal data to third-party marketers or data brokers. bt111 shares your personal data with third parties only in the following circumstances and to the extent strictly necessary:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency payment processors receive the transactional data necessary to process your deposits and withdrawals. Each payment processor operates under its own privacy policy and is responsible for the security of data within its own systems.
• Identity Verification Providers: Third-party KYC and identity verification services engaged by bt111 receive the identity and document data necessary to complete the verification of member accounts.
• Gaming Software Providers: The providers of casino games, slot titles, live dealer software, and arcade game platforms may receive anonymised session and gameplay data necessary for game operation and audit logging.
• Fraud and AML Services: Third-party fraud detection, anti-money laundering screening, and responsible gaming monitoring services receive the data necessary to perform their contracted services.
• Regulatory and Law Enforcement Authorities: bt111 may be required by law, court order, or regulatory authority to disclose personal data. bt111 will comply with such requirements to the extent mandated by applicable law.
• Professional Advisers: bt111's legal counsel, auditors, and professional advisers may have access to personal data where necessary in connection with their professional engagements, subject to binding confidentiality obligations.

The bt111 platform uses cookies and similar tracking technologies to operate core platform functions, remember your preferences, maintain your login session, detect fraud, and analyse platform usage. A cookie is a small text file placed on your device by the bt111 server when you visit the bt111 website.

8.1 Types of Cookies Used by bt111

• Strictly Necessary Cookies: Required for the basic operation of the bt111 platform, including maintaining your authenticated login session, processing transactions, and enforcing security measures. These cookies cannot be disabled without materially impairing your ability to use bt111.
• Functional Cookies: Used to remember your preferences such as game category, display language, and responsible gaming limit settings. These enhance your experience but are not strictly required for platform operation.
• Analytics Cookies: Used by bt111 to understand how members interact with the platform — which features are most used, how long sessions last, and where users encounter friction — so that bt111 can continuously improve the platform experience.
• Security Cookies: Used for fraud detection, duplicate account identification, and the monitoring of suspicious access patterns that may indicate account compromise.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from accessing core bt111 platform features, including the bt111 Login functionality and wallet transactions.

bt111 retains personal data only for as long as is necessary for the purposes for which it was collected, or for as long as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained throughout the duration of your active bt111 membership and for a period of not less than five (5) years following the closure of your account, to satisfy gaming licence and AML regulatory retention requirements.
• Transaction and Financial Records: Retained for a minimum of seven (7) years from the date of the transaction, in compliance with financial record-keeping obligations applicable under bt111's international gaming licence.
• KYC and Identity Verification Documents: Retained for the duration of the member relationship and for a minimum of five (5) years following account closure.
• Customer Support Communications: Retained for a period of three (3) years from the date of the final communication in a given support interaction.
• Technical and Usage Logs: Retained for a maximum of thirteen (13) months from the date of collection, after which they are aggregated or deleted.
• Marketing Preference Data: Retained until you withdraw your marketing consent, at which point it is updated to reflect your opt-out status and retained as a record of the withdrawal of consent.

bt111 implements a multi-layered technical and organisational security framework to protect personal data against unauthorised access, disclosure, alteration, loss, and destruction. bt111's security measures include, but are not limited to:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the bt111 platform, ensuring that credentials, payment data, and personal information are never transmitted in plain text;
• AES-256 encryption applied to sensitive data fields stored in bt111 databases, including financial data and identity documents;
• Role-based access controls ensuring that only authorised bt111 personnel with a documented business need may access personal data, and only to the minimum extent necessary for their role;
• Two-factor authentication (2FA) availability for all member accounts, providing an additional layer of protection against unauthorised account access;
• Continuous automated monitoring for suspicious access patterns, brute-force login attempts, and anomalous data access events;
• Regular security audits and penetration testing conducted by independent third-party security specialists;
• Staff data protection training and confidentiality obligations binding all bt111 employees and contractors who handle personal data.

Subject to applicable law and bt111's regulatory obligations, you hold the following rights with respect to your personal data held by bt111:

• Right of Access: You may request a copy of the personal data bt111 holds about you, together with information about how that data is used and on what legal basis;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held by bt111. For routine account information updates, you may make corrections directly from your bt111 account dashboard;
• Right to Erasure: You may request deletion of your personal data where bt111 no longer has a legal basis for its continued retention. Note that bt111 may be required to retain certain data for mandatory periods as described in Section 9, notwithstanding an erasure request;
• Right to Restrict Processing: You may request that bt111 restrict the processing of your data in certain circumstances, for example while a dispute about data accuracy is being resolved;
• Right to Data Portability: You may request that bt111 provide a machine-readable copy of personal data you have provided to bt111, where processing is based on consent or contractual necessity;
• Right to Object: You may object to processing of your personal data carried out on the basis of bt111's legitimate interests. bt111 will cease such processing unless compelling legitimate grounds exist that override your interests;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact the bt111 data protection team using the contact details provided in Section 15 of this policy. bt111 will respond to all valid privacy rights requests within thirty (30) calendar days of receipt. In cases of complexity or high volume, bt111 may extend this period by a further thirty (30) days, with written notification to the requesting member.

bt111 enforces strict age verification at the point of registration and reserves the right to request documentary proof of age at any stage of the member relationship. Where bt111 discovers or has reasonable grounds to believe that a registered member is under the age of 21, bt111 will immediately suspend the account, initiate a full review, and where confirmed, permanently close the account and return any verifiable deposits to the payment source, subject to applicable KYC and AML requirements.

Any personal data inadvertently collected from an individual found to be under the age of 21 will be deleted from bt111's systems as promptly as practicable following discovery. If you are a parent or guardian and believe your child may have registered a bt111 account, please contact bt111 customer support immediately at [email protected].

bt111 operates as an international online gaming platform. As a consequence of this international operation, your personal data may be transferred to, stored in, or processed in countries other than Pakistan, including the jurisdiction in which bt111 holds its gaming licence and the jurisdictions in which bt111's technology infrastructure and third-party service providers are located.

Where bt111 transfers personal data outside Pakistan to third countries, bt111 ensures that appropriate safeguards are in place to protect the privacy rights of affected members. These safeguards may include contractual data protection clauses binding the recipient to data handling standards equivalent to those maintained by bt111, or reliance on the recipient country's recognition as providing an adequate level of data protection.

By using the bt111 platform, you acknowledge and consent to the transfer of your personal data to other countries for the purposes described in this Privacy Policy, subject to the safeguards described above.

bt111 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, bt111's data processing practices, or the products and services offered on the platform. The effective date displayed at the top of this document reflects the date of the most recent revision.

Where bt111 makes a material change to this Privacy Policy — that is, a change that significantly affects your privacy rights or bt111's data processing practices — bt111 will notify affected members via email to the registered account address and/or via a prominent in-platform notification, with a minimum of 14 calendar days' notice before the revised policy takes effect.

For minor amendments — including typographical corrections, clarifications of existing provisions, or changes required for regulatory compliance — bt111 may update the policy without advance notice. Your continued use of the bt111 platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy.

bt111 recommends that members review this Privacy Policy periodically to stay informed of how their personal data is being handled. The date of the most recent review is displayed in the effective date bar at the top of the legal content section.

For any questions, requests, or concerns relating to this Privacy Policy or bt111's data processing practices, please contact the bt111 data protection team through the following channel:

bt111 is committed to resolving all privacy-related concerns directly with affected members. If you remain dissatisfied with bt111's handling of your privacy concern after raising it with the bt111 data protection team, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

For Pakistani members with concerns about data protection, bt111 will cooperate in good faith with any enquiries made through appropriate regulatory channels. bt111 values the trust its Pakistani member community places in the platform and treats every privacy concern as a matter of serious importance.