ph111 Privacy Policy — Your Data, Our Responsibility

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by ph111 ("Platform", "we", "us") and applies to all personal data we collect from individuals ("players", "you") who register an account on ph111.onl, use our online casino games, place sports bets, make deposits or withdrawals via bKash, Nagad, Rocket or supported bank channels, or otherwise interact with the ph111 platform and its associated services.

By registering a ph111 account or using the Service, you acknowledge that you have read this Policy in full, that you understand how your personal data will be processed, and that you consent to that processing as described herein. If you do not agree with this Policy you must not register an account or use the Service. This Policy forms part of ph111's Terms and Conditions by reference.

2. Data Controller

ph111 is the data controller responsible for the personal data it collects and processes. ph111 operates as a digital platform exclusively serving players in Bangladesh. For all privacy-related inquiries, contact ph111's data team at [email protected].

ph111 processes personal data lawfully, fairly and transparently. The primary legal bases on which ph111 relies for processing are: (a) performance of the contract between ph111 and the player — account management, payment processing, game provision; (b) compliance with legal obligations — KYC, AML; and (c) the player's consent — marketing communications and non-essential cookies.

ph111 will not process your personal data for any purpose that is incompatible with the purposes for which it was originally collected, unless you provide explicit fresh consent or a legal obligation requires the additional processing.

3. Personal Data We Collect

ph111 collects personal data in two ways: data you provide directly, and data collected automatically when you use the platform. The categories of personal data we collect are limited to what is necessary for the purposes described in Section 4:

• Registration data: your full legal name (as it appears on your NID or passport), Bangladeshi mobile number, date of birth, and a password of your choosing — provided by you at account creation.
• KYC verification data: a copy of your National Identity Card (NID) or passport and a recent proof of address — collected when you initiate a withdrawal or when ph111 is required to conduct enhanced due diligence.
• Financial transaction data: records of deposits and withdrawals including payment method used (bKash, Nagad, Rocket, Upay or bank account details), transaction amounts, reference numbers and timestamps.
• Gaming activity data: records of bets placed (game type, market, stake, result, settlement), session start and end times, game history, bonus claims and usage, and responsible gaming tool settings such as deposit limits and self-exclusion status.
• Technical and device data: your IP address, device type, operating system, browser type, screen resolution, network carrier (e.g. Grameenphone, Robi, Banglalink), time zone (Bangladesh Standard Time, UTC+6), and session activity logs — collected automatically when you access ph111.

ph111 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data or health data unless expressly required by applicable law for a specific compliance purpose.

4. How We Use Your Personal Data

ph111 uses the personal data it collects strictly for the following purposes. We do not use your data for any purpose inconsistent with these stated purposes without your explicit consent:

• Account management and service delivery: creating and maintaining your ph111 player account; verifying your identity and age; processing deposits and withdrawals; providing access to casino games, sports betting markets and promotional offers; and sending account-related notifications via SMS to your registered mobile number.
• Legal and regulatory compliance: conducting KYC checks; fulfilling AML obligations; complying with any valid legal request from a competent authority; and maintaining transaction records for legally required retention periods.
• Security and fraud prevention: detecting and preventing unauthorised access to player accounts; identifying and blocking fraudulent transactions, duplicate accounts and bonus abuse; and protecting the integrity of ph111's gaming platform.
• Marketing and promotions (consent-based): sending promotional SMS messages about bonuses, new games, BPL and IPL cricket betting promotions and seasonal offers to players who have opted in. Players who have not opted in will not receive promotional SMS from ph111. Marketing consent may be withdrawn at any time by contacting ph111 support.
• Platform improvement: analysing aggregated, anonymised usage data to understand how players interact with the ph111 platform and to improve the platform experience for all Bangladesh players. This analysis does not involve profiling individual players in a way that produces legal or similarly significant effects.

5. Data Sharing and Third-Party Processors

ph111 shares personal data with third parties only to the extent strictly necessary to deliver the Service, comply with legal obligations, or protect the platform from fraud. All third-party data processors are bound by confidentiality agreements and are prohibited from using player data for any purpose other than the specific service they provide to ph111. Categories of third party with whom ph111 may share your data include:

• Payment service providers: bKash, Nagad, Rocket and Upay (and their respective banking infrastructure partners) receive the minimum transaction data required to process deposits and withdrawals. They do not receive your gaming activity data or KYC documents.
• KYC and identity verification providers: third-party identity verification services that process copies of your NID and address documents to confirm your identity and age. These providers operate under strict data processing agreements and are certified for secure document handling.
• Anti-fraud and AML screening providers: services that screen transaction patterns against known fraud indicators and financial crime databases. These providers receive transaction metadata and IP data only — they do not receive your KYC documents or gameplay history.
• Law enforcement and regulatory authorities: where ph111 is legally compelled to disclose personal data — for example in response to a valid court order or a formal request from a financial intelligence unit — ph111 will provide the minimum data required to satisfy the legal obligation and will notify the affected player to the extent permitted by law.

All data sharing is governed by written data processing agreements that require processors to implement technical and organisational security measures equivalent to those ph111 applies internally. ph111 does not transfer personal data to recipients outside the arrangements described in this Section.

6. Data Security

ph111 implements a multi-layered approach to data security. The following technical and organisational measures are in place to protect your personal data against unauthorised access, accidental loss, destruction or disclosure:

• TLS/SSL encryption in transit: all data transmitted between your mobile browser and ph111 servers is protected by TLS. The ph111 website enforces HTTPS on every page and redirects any unencrypted HTTP connection automatically.
• Encrypted storage: sensitive personal data — including NID document copies, financial account identifiers (bKash/Nagad wallet numbers) and passwords — is stored in encrypted form. Passwords are stored as salted cryptographic hashes; ph111 staff cannot retrieve your plaintext password at any time.
• Access controls: access to personal data within ph111's internal systems is restricted on a need-to-know basis. Only staff members who require access to perform their specific job function are granted access. All internal access events are logged and audited.
• Intrusion detection and monitoring: ph111's servers are monitored continuously for signs of intrusion, anomalous access patterns and attempted data exfiltration. Security incidents are escalated to ph111's technical team immediately upon detection.
• Breach notification: in the event of a personal data breach that is likely to result in risk to affected players, ph111 will notify them via SMS to their registered mobile number within a reasonable time after becoming aware of the breach, describing the nature of the breach, data categories affected and the steps taken to mitigate the impact.

While ph111 implements robust security measures, no digital platform can guarantee absolute security against all possible threats. You are responsible for keeping your own ph111 account credentials secure and not sharing your login details with any third party. If you suspect your account has been compromised, contact ph111 support immediately.

7. Cookies and Tracking Technologies

ph111 uses cookies and similar tracking technologies on its website. A cookie is a small text file placed on your device when you visit a website. ph111 uses the following categories of cookies:

• Strictly necessary cookies: required for the ph111 website to function and cannot be disabled. They include session authentication cookies, security cookies and load-balancing cookies. These cookies do not collect personal data beyond what is strictly required for platform operation.
• Analytics cookies: ph111 uses anonymised analytics cookies to understand aggregate player behaviour — pages visited, session duration, feature engagement and error rates. The data is anonymised before storage and cannot be used to identify individual players. These cookies may be disabled via your browser settings without affecting platform functionality.
• Functional cookies: remember your account preferences — language setting, responsible gaming tool configurations and display preferences — so the platform behaves consistently across sessions without requiring you to reconfigure preferences each time you log in.
• ph111 does not use third-party advertising cookies or social media tracking pixels and does not participate in cross-site behavioural advertising networks. No cookie placed by ph111 is used to track you across websites other than ph111.onl. You may manage or delete cookies at any time via your mobile browser settings.

Disabling strictly necessary cookies will prevent you from logging into your ph111 account. Disabling analytics or functional cookies will not prevent access to the platform but may affect the consistency of your experience across sessions.

8. Data Retention

ph111 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by applicable law. The following retention principles apply:

• Active account data: personal data associated with an active ph111 account is retained for the full duration of the account's active life and for a minimum of 5 years after the account is closed, to satisfy AML record-keeping requirements and to handle any post-closure disputes or regulatory inquiries.
• KYC documents: identity and address verification documents are retained for the same 5-year post-closure minimum as other account data, as required for AML compliance. Documents are stored in encrypted form throughout the retention period.
• Transaction records: financial transaction records are retained for a minimum of 5 years after the date of each transaction, consistent with standard financial record-keeping obligations.
• Anonymised analytics data: aggregated, anonymised platform usage data — from which individual players cannot be identified — is retained indefinitely for product development and historical performance analysis. The original identifiable form is not retained beyond its operational purpose.

When any retention period expires, ph111 will either securely delete the data or irreversibly anonymise it. Secure deletion involves overwriting stored data so that it cannot be recovered. Anonymisation removes all direct and indirect identifiers so that the remaining data cannot reasonably be attributed to an identifiable individual.

9. Your Data Rights

As a ph111 player you have the following rights with respect to your personal data. To exercise any of these rights, contact ph111 support by email at [email protected], clearly stating the right you wish to exercise and your registered mobile number for identity verification:

• Right of access: you may request a copy of the personal data ph111 holds about you. ph111 will respond to access requests within 30 days of receipt, describing the categories of data held, the purposes for which it is processed and any third parties to whom it has been disclosed.
• Right of rectification: if any personal data ph111 holds about you is inaccurate or incomplete, you may request that it be corrected or completed. ph111 will action rectification requests within 14 days of receipt. Rectification of KYC data may require you to submit updated documentation.
• Right of erasure: you may request that ph111 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (for consent-based processing), or where you object to processing and there is no overriding legitimate interest. ph111 will assess erasure requests against applicable legal retention obligations and respond within 30 days.
• Right to restrict processing: you may request that ph111 restrict the processing of your personal data in certain circumstances — for example while the accuracy of data is being contested, or while an objection to processing is being assessed. Restriction means ph111 will store the data but will not actively process it during the restriction period.
• Right to withdraw marketing consent: if you have previously opted in to receive promotional SMS from ph111, you may withdraw that consent at any time by emailing [email protected]. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out before the withdrawal.

ph111 will verify your identity before acting on any data rights request to ensure that personal data is not disclosed to or modified by an unauthorised third party. ph111 will not charge a fee for responding to data rights requests in ordinary circumstances.

10. Children and Minors

ph111 is strictly an adult platform. The minimum age for registration and use of the Service is 21 years. ph111 does not knowingly collect personal data from any individual under the age of 21. During registration, ph111 collects your date of birth and cross-checks it against the KYC documents you provide; accounts belonging to individuals under 21 are terminated upon discovery.

If you are a parent or guardian and believe that your child (under 21) has registered a ph111 account or provided personal data to ph111, please contact ph111 support immediately at [email protected]. ph111 will investigate, terminate the account if the user is found to be under 21, and securely delete the associated personal data, subject to any mandatory legal retention obligations.

11. Changes to This Privacy Policy

ph111 reviews this Privacy Policy periodically and may update it to reflect changes in our data practices, changes in the services we provide, or to comply with updated legal or regulatory requirements. When material changes are made to this Policy, ph111 will notify registered players via SMS to their registered mobile number at least 7 days before the revised Policy takes effect. The updated Policy will be published on this page with a revised "Last updated" date. Your continued use of ph111 after the effective date constitutes your acceptance of the revised Policy.

If you do not accept a revised version of this Policy, you must stop using the Service and contact ph111 support to arrange closure of your account. ph111 will not make retroactive changes to this Policy that reduce your data rights or increase ph111's data collection scope without your explicit fresh consent.

12. Contact and Complaints

If you have any question about this Privacy Policy, wish to exercise a data right, or want to report a privacy concern, please email ph111's data team at [email protected]. Please include the word "Privacy" in your email subject line and provide your registered mobile number so that we can verify your identity before responding. ph111 will acknowledge privacy-related inquiries within 5 business days (Bangladesh Standard Time, Monday to Friday) and aims to provide a substantive response within 28 days of receipt.

This Privacy Policy forms part of ph111's Terms and Conditions by reference. In the event of any conflict between this Policy and the Terms and Conditions on the specific subject of personal data processing, this Policy shall prevail to the extent of that inconsistency. The current Terms and Conditions are available at ph111.onl/terms-conditions. You are encouraged to read both documents before registering a ph111 account.

13. Glossary

For the purposes of this Privacy Policy the following terms have the following meanings: "Personal data" means any information relating to an identified or identifiable natural person. "Processing" means any operation performed on personal data, including collection, storage, use, disclosure and deletion. "Controller" means the entity that determines the purposes and means of the processing of personal data. "Processor" means an entity that processes personal data on behalf of a controller under a written data processing agreement. "AML" means anti-money laundering. "KYC" means Know Your Customer — the process of verifying a player's identity and source of funds.

"SSL" means Secure Sockets Layer — an encryption protocol that protects data transmitted over the internet. "TLS" means Transport Layer Security — the updated successor to SSL providing equivalent encryption protections. "Bangladesh Standard Time (BST)" means the time zone at UTC+6, which is the standard time zone for all ph111 operations and communications. All timestamps in player account records and support communications are expressed in Bangladesh Standard Time (UTC+6).