ek111 Privacy Policy

1. Introduction

This Privacy Policy describes how ek111 ("we", "us", "our", or "the Platform") collects, processes, stores, and protects the personal data of individuals ("you" or "Player") who register for or use the ek111 online betting and casino platform available at ek111.io.

By creating an account or using any service on the ek111 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this policy, you should not access or use the ek111 platform.

This policy should be read alongside the ek111 Terms & Conditions, which govern your use of the platform more broadly. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a data-related matter, this Privacy Policy shall take precedence.

2. Data Controller

For the purposes of this Privacy Policy, ek111 acts as the data controller in respect of personal data collected from players using the ek111.io platform. As data controller, ek111 determines the purposes and means by which your personal data is processed.

If you have any questions about the identity of the data controller, or wish to exercise any of the data rights set out in Section 10 of this policy, please contact us using the details provided in Section 14.

3. Data We Collect

ek111 collects personal data in two primary ways: information you provide directly to us, and information we collect automatically when you use the platform. The table below summarises the main categories of data we collect.

3.1 Sensitive Personal Data

ek111 does not intentionally collect sensitive personal data (such as racial or ethnic origin, religious beliefs, health information, or political opinions) from players. Where identity documents submitted for KYC may incidentally contain such information (for example, religion listed on a Bangladesh National ID card), that information is not separately processed or stored beyond what is required for identity verification purposes.

4. How We Use Your Data

ek111 uses the personal data it collects for the following purposes:

• Account Management: To create and manage your ek111 account, verify your identity, process deposits and withdrawals, and communicate account-related information to you.
• KYC & Compliance: To verify that you meet the minimum age requirement of 21 years, to comply with anti-money-laundering (AML) obligations, and to fulfil any other applicable legal or regulatory requirements.
• Service Delivery: To provide access to betting markets, casino games, card games, and other features available on the ek111 platform.
• Customer Support: To respond to your enquiries, complaints, and support requests via email or WhatsApp.
• Platform Security: To detect, investigate, and prevent fraudulent activity, account abuse, collusion, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gaming: To monitor gambling patterns and intervene where necessary to support responsible gaming, including applying self-exclusion requests and deposit limit settings.
• Marketing & Promotions: To send you relevant promotional offers, including BPL betting promotions, Eid bonuses, and seasonal campaigns — but only where you have opted in to receive such communications.
• Platform Improvement: To analyse aggregate usage data, improve user experience, and optimise the performance and content of the ek111 platform.

5. Legal Basis for Processing

ek111 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing of identity, contact, financial, and account data is necessary to perform our contractual obligations to you as a registered ek111 player.
• Legal Obligation: Processing of KYC documents and transaction records is required to comply with applicable anti-money-laundering, counter-terrorism financing, and age verification obligations.
• Legitimate Interests: Processing of technical data and account activity data is carried out in ek111's legitimate interest in maintaining platform security, preventing fraud, and improving service quality.
• Consent: Processing of your data for direct marketing purposes is carried out only where you have provided explicit opt-in consent. You may withdraw your marketing consent at any time by updating your account communication preferences or contacting our support team.

6. Data Sharing

ek111 does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. We may share your data with the following categories of trusted third parties, strictly for the purposes outlined in this policy:

• Payment Service Providers: Including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Visa, and Mastercard — to process deposits and withdrawals on your behalf.
• Game Content Providers: Including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — who may receive anonymised session identifiers necessary for game delivery and fair-play auditing.
• Technology & Infrastructure Providers: Cloud hosting, content delivery, and cybersecurity vendors who process data on our behalf under strict data processing agreements.
• Legal & Regulatory Authorities: Where required by law, court order, or regulatory direction, ek111 may disclose your personal data to law enforcement or other governmental authorities in Bangladesh or other applicable jurisdictions.
• Fraud Prevention Services: Third-party fraud detection and identity verification services used during the KYC and AML screening processes.

All third-party service providers who receive your personal data are contractually required to process it only in accordance with ek111's instructions and to maintain appropriate security standards.

7. Cookies & Tracking Technologies

ek111 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files placed on your device when you visit ek111.io. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function, including session management, authentication, and security. These cookies cannot be disabled without affecting core platform functionality.
• Performance Cookies: Used to collect anonymised data about how players navigate the platform, which pages are visited most frequently, and where errors occur. This information helps us improve the ek111 user experience.
• Functional Cookies: Used to remember your preferences, such as language settings, preferred game categories, and responsible gaming limits you have set.
• Marketing Cookies: Used to track whether you have clicked on a promotional offer and to ensure that the same promotion is not shown to you repeatedly. These cookies are only placed where you have consented to receive marketing communications.

You can manage your cookie preferences via your browser settings. Please note that disabling certain cookies may affect the availability or performance of some ek111 platform features.

8. Data Security

ek111 implements a comprehensive set of 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 transmitted between your device and the ek111 platform.
• Encrypted storage of sensitive personal data, including National ID documents and financial information, in access-controlled server environments.
• Role-based access controls ensuring that only authorised ek111 personnel with a legitimate business need can access specific categories of player data.
• Regular security audits, penetration testing, and vulnerability assessments of the ek111 platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Comprehensive employee training on data protection obligations and information security best practices.

While ek111 takes all reasonable precautions to protect your data, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, ek111 will notify affected players without undue delay and will take all appropriate remediation steps.

9. Data Retention

ek111 retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. The following general retention periods apply:

• Account and Transaction Data: Retained for a minimum of five (5) years following account closure, in compliance with financial record-keeping and AML requirements.
• KYC Identity Documents: Retained for a minimum of five (5) years from the date of submission, or longer if required by applicable regulatory guidance.
• Customer Support Communications: Retained for three (3) years from the date of the last interaction, to facilitate resolution of any future disputes or complaints.
• Marketing Consent Records: Retained for as long as your account remains active, and for two (2) years following any withdrawal of marketing consent.
• Technical and Log Data: Retained for up to twelve (12) months, unless required for longer by a specific security investigation or legal proceeding.

When your personal data is no longer required for any applicable retention purpose, ek111 will securely delete or anonymise it in accordance with our internal data disposal procedures.

10. Your Rights

As an ek111 player, you have the following rights in respect of your personal data. To exercise any of these rights, please contact our support team using the details in Section 14.

• Right of Access: You may request a copy of the personal data ek111 holds about you, along with information about how it is being processed.
• Right to Rectification: You may request that any inaccurate or incomplete personal data held by ek111 be corrected or updated.
• Right to Erasure: You may request that ek111 delete your personal data where it is no longer necessary for the purpose for which it was collected, subject to any overriding legal retention obligations.
• Right to Restriction of Processing: You may request that ek111 restrict the processing of your personal data in certain circumstances, for example while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on your consent or on a contractual basis, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time, without providing any specific reason. You may also object to processing based on legitimate interests, though ek111 may be required to continue processing where compelling legitimate grounds override your interests.
• 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.

ek111 will respond to all data rights requests within 28 calendar days of receipt. In complex cases, we may extend this period by a further 28 days, in which case we will notify you of the extension and the reason for it.

11. Children's Privacy

The ek111 platform is strictly intended for adults aged 21 years and above. ek111 does not knowingly collect personal data from persons under the age of 21. Our registration and KYC processes are specifically designed to verify that all players meet this minimum age requirement.

If ek111 becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all associated data will be reviewed, and any funds held in the account will be subject to the procedures set out in our Terms & Conditions regarding underage accounts.

Parents or guardians who believe that a minor has registered on the ek111 platform should contact our support team immediately at [email protected] so that the matter can be investigated and resolved without delay.

12. Third-Party Links

The ek111 platform does not include links to third-party websites for advertising or affiliate purposes. Where references to third-party payment providers (such as bKash, Nagad, or Rocket) or game developers (such as Pragmatic Play or Evolution Gaming) appear on the platform, these are included solely for informational context and do not constitute endorsement of, or responsibility for, the privacy practices of those third parties.

ek111 is not responsible for the privacy policies or practices of any third-party service providers. Players who access third-party services (for example, their bKash mobile banking application) should review the relevant third-party privacy policies independently.

13. Policy Amendments

ek111 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the ek111 platform. The revised policy will take effect from the date specified in the update notice.

Your continued use of the ek111 platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms. We recommend that you review this page periodically to stay informed of any changes. The "Last Updated" date at the top of this section indicates when the policy was most recently revised.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 10, please contact the ek111 privacy and data protection team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line
• WhatsApp: +880 1700 000 111 — available 24 hours a day, 7 days a week
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6)

We aim to acknowledge all privacy-related enquiries within 2 business days and to provide a substantive response within 28 calendar days. For complex data rights requests — such as full data access requests or erasure requests involving multiple data categories — we may take up to 56 calendar days, and we will inform you if an extension is required.

If you are not satisfied with our response to your privacy concern, you have the right to escalate the matter through applicable legal channels in Bangladesh. ek111 takes all privacy complaints seriously and is committed to resolving them promptly and fairly.