Privacy Policy — 1111bte

For the purposes of this Privacy Policy, the data controller — the entity that determines the purposes and means of processing your personal data — is 1111bte, the operator of the online casino and sports betting platform accessible at 1111bte (the "Platform").

All privacy-related correspondence, data access requests, and complaints should be directed to our support team at: support@1111bte. We aim to acknowledge all privacy enquiries within 5 business days and to provide a substantive response within 20 business days.

1.1 Legal Bases for Processing

1111bte processes your personal data under one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing that is required to fulfil the terms of the player agreement between you and 1111bte — including account creation, payment processing, and withdrawal management.
• Legal obligation: Processing that is required to comply with applicable laws and regulations, including Know Your Customer (KYC) identity verification, anti-money laundering (AML) checks, and fraud prevention requirements.
• Legitimate interests: Processing undertaken to protect the security and integrity of the Platform, to prevent fraud and abuse, to improve platform performance, and to analyse game and betting usage patterns for responsible gaming purposes — where those interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as sending you promotional emails, newsletters, and personalised bonus offers — where you have given explicit, informed consent that you may withdraw at any time.

1.2 Scope of This Policy

This Privacy Policy applies to all personal data collected through the 1111bte website, mobile-optimised interface, live chat support interactions, email correspondence with support@1111bte, and any other digital touchpoint operated by 1111bte. It does not apply to third-party websites or services that may be linked from the Platform — those third parties operate under their own privacy policies, for which 1111bte accepts no responsibility.

1111bte collects personal data in three primary ways: directly from you when you register and use the Platform; automatically through your device and browser when you interact with our website; and from third-party sources such as payment providers and fraud prevention services. The following table summarises the categories of personal data we collect and the context in which each is gathered.

2.1 Data We Do Not Collect

1111bte does not collect or process the following categories of sensitive personal data, and you must not submit them voluntarily: racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data (beyond standard KYC photo ID), health data (beyond responsible gaming self-disclosures), or sexual orientation. If any such data is inadvertently submitted, it will be deleted without use.

2.2 Data from Minors

1111bte is strictly an adults-only platform (18+). We do not knowingly collect personal data from any individual under the age of 18. If we discover that data belonging to a minor has been collected — through a fraudulent registration — that data and the associated account will be immediately deleted and the matter may be reported to relevant authorities. If you are a parent or guardian and believe your child has registered on this Platform, please contact us immediately at support@1111bte.

Every use of your personal data by 1111bte is tied to a specific, documented purpose. We do not use your data in ways that are incompatible with those purposes without first seeking your consent. The following outlines the primary purposes for which we process your personal data and the legal basis that applies to each.

3.1 Account Management and Platform Operation

We use your registration data, payment data, and technical data to create and maintain your player account, authenticate your login sessions, process your deposits and withdrawals in BDT, display your game history and account balance, and provide you with access to all features of the 1111bte platform. This processing is necessary to fulfil our contractual obligations to you as a registered player.

3.2 Identity Verification and Legal Compliance

We use your KYC documents and payment data to verify your identity, confirm that you meet the 18+ age requirement, conduct anti-money laundering (AML) checks, and comply with fraud prevention obligations. This processing is required by law and cannot be opted out of — players who do not complete KYC verification will have withdrawal access restricted. KYC data is handled with the highest level of confidentiality and is not used for any other purpose.

3.3 Fraud Prevention and Platform Security

We use technical data, payment data, and gameplay data to detect and prevent fraudulent activity, identify multi-accounting, monitor for bonus abuse, and protect the security and integrity of the Platform for all players. This processing is conducted under our legitimate interests in operating a secure and fair gaming environment. Where fraud is confirmed, relevant data may be shared with law enforcement as described in Section 4.

3.4 Responsible Gaming

We use gameplay data, session data, and responsible gaming self-disclosure data to monitor for indicators of problem gambling behaviour, enforce self-imposed limits, implement cooling-off periods and self-exclusion requests, and send responsible gaming prompts where harmful play patterns are detected. This processing is conducted under both contractual and legitimate interests grounds and reflects our genuine commitment to player wellbeing. See our dedicated Responsible Gaming page for full details.

3.5 Customer Support

We use communication data, account data, and payment data to respond to your support enquiries, resolve disputes, investigate complaints, and maintain a record of your support interactions for quality and training purposes. This processing is necessary for the performance of our contract with you.

3.6 Platform Improvement and Analytics

We use aggregated, anonymised gameplay data, device data, and technical data to understand how players use the Platform, identify performance issues, improve game loading speeds and navigation, and develop new features. Where this analysis uses identifiable data rather than fully anonymised datasets, it is conducted under our legitimate interests and can be objected to by contacting support@1111bte.

3.7 Marketing Communications (Consent-Based)

With your explicit consent — provided during registration or via your account communication preferences — we may send you promotional emails, bonus offers, seasonal promotions (such as Eid, Pohela Boishakh, or BPL season promotions), and platform news. You may withdraw your marketing consent at any time by clicking the "Unsubscribe" link in any marketing email or by contacting support@1111bte. Withdrawal of marketing consent does not affect our ability to send you service-related account communications, which are necessary regardless of consent.

There are limited, specific circumstances in which 1111bte shares personal data with third parties. In every case, data sharing is limited to what is strictly necessary for the stated purpose, and recipient parties are required to handle your data with the same level of protection as 1111bte.

4.1 Payment Processors

To process your deposits and withdrawals in BDT, we share the minimum necessary transaction data with your chosen payment provider — bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, or BRAC Bank. The data shared is limited to your registered mobile number or bank account identifier and the transaction amount. Payment processors operate under their own privacy policies and are responsible for their own data security practices.

4.2 Game and Technology Providers

To deliver the games and services on our Platform, certain technical identifiers (such as a session token and anonymised player ID) are passed to our game studio partners — including Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, Microgaming, and Spribe. These identifiers are used solely for the purpose of delivering and recording game rounds. No personally identifiable information (name, email, payment details) is shared with game providers unless required for the resolution of a specific dispute.

4.3 Identity Verification Services

To complete KYC checks, we use trusted third-party identity verification service providers who process your KYC documents on our behalf. These providers act as data processors under our instruction and are contractually prohibited from using your KYC data for any purpose beyond identity verification for 1111bte. KYC documents are never shared with game providers, marketing partners, or other third parties.

4.4 Fraud Prevention Networks

To detect and prevent multi-accounting, bonus abuse, and payment fraud, 1111bte may share technical identifiers — such as device fingerprints, IP addresses, and hashed email addresses — with fraud prevention partners and industry shared-risk databases. This sharing is conducted under our legitimate interests in maintaining a fair and secure Platform. Individual personally identifiable information (full name, payment details) is not shared with fraud networks except where a confirmed fraud incident requires reporting to law enforcement.

4.5 Legal and Regulatory Disclosure

1111bte will disclose personal data to law enforcement agencies, courts, regulatory authorities, or other government bodies where required to do so by applicable law, court order, or lawful regulatory request. We will make reasonable efforts to notify affected players of such disclosures where permitted to do so by law, but we are not required to do so where disclosure is under a legal order of secrecy or where notification would obstruct an investigation.

4.6 Business Transfers

In the event that 1111bte undergoes a merger, acquisition, restructuring, or sale of all or substantially all of its business assets, player data may be transferred to the acquiring entity as part of that transaction. We will notify registered players by email at least 30 days before any such transfer takes effect and will ensure that the acquiring entity provides equivalent data protection commitments to those set out in this Privacy Policy.

1111bte uses cookies and similar tracking technologies to operate the Platform, maintain your login session, remember your preferences, and analyse how the Platform is used. This section explains the types of cookies we use and how you can manage your cookie preferences.

5.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognise your device on subsequent visits, remember your preferences, and maintain your session state. Cookies do not contain executable code and cannot access other files on your device. Similar technologies include web beacons (transparent pixel images used to track email opens) and local storage objects, which function in a comparable way to cookies.

5.2 Cookie Categories We Use

5.3 Managing Your Cookie Preferences

You can control non-essential cookies through your browser settings. Most modern browsers allow you to refuse all cookies, accept only certain types, or delete existing cookies. Please note that disabling essential or security cookies will impair your ability to use the Platform — you may not be able to log in or maintain a session. For analytics cookies specifically, you can opt out by contacting us at support@1111bte with the subject line "Cookie Opt-Out Request".

5.4 No Cross-Site Advertising Tracking

1111bte does not use advertising cookies, retargeting pixels, or third-party social media tracking scripts that follow you across other websites after you leave the Platform. Our analytics cookies are used solely to improve 1111bte's own services and are not shared with advertising networks or data brokers.

1111bte retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply to different categories of data held on our Platform.

6.1 Deletion After Retention Period

Once the applicable retention period expires, personal data is either securely deleted from our systems or anonymised — meaning it is stripped of all identifying information so that it can no longer be linked back to you. Anonymised data (for example, aggregated gameplay statistics) may be retained indefinitely for platform analytics and responsible gaming research purposes.

6.2 Data Pertaining to Ongoing Investigations

Where a player account is under active investigation for fraud, AML, or a regulatory matter, the relevant data will be retained until the investigation is fully resolved, regardless of whether the standard retention period has expired. We will not delete data that is subject to a legal hold or court order.

1111bte takes data security seriously and implements a layered set of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. No system can guarantee absolute security, but the following measures reflect our commitment to industry-standard data protection practice.

8.1 Technical Security Measures

• Transport encryption: All data transmitted between your browser and 1111bte is protected by 256-bit TLS (Transport Layer Security) encryption. The padlock icon in your browser confirms this protection is active.
• Data-at-rest encryption: Personal data stored in our databases is encrypted using AES-256 encryption. Encryption keys are managed separately from the encrypted data and rotated on a regular schedule.
• Password hashing: Account passwords are never stored in plain text. They are hashed using a modern, salted one-way hashing algorithm. Even our own technical staff cannot retrieve your plain-text password.
• Firewalls and intrusion detection: Our infrastructure is protected by enterprise-grade firewalls and 24/7 intrusion detection systems that flag anomalous access patterns for immediate investigation.
• Access controls: Access to personal data within the 1111bte organisation is strictly role-based and governed by the principle of least privilege. Only personnel with a documented operational need are granted access to identifiable player data.
• Penetration testing: We conduct periodic security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.

8.2 Organisational Security Measures

• All staff with access to personal data undergo data protection training and are bound by confidentiality obligations in their employment contracts.
• Third-party service providers who process personal data on our behalf are subject to data processing agreements that impose security standards equivalent to those we apply internally.
• We maintain an internal data breach response procedure. In the event of a breach that is likely to result in a risk to player rights and freedoms, affected players will be notified without undue delay.
• Physical access to servers and infrastructure is restricted to authorised personnel only, with access logs maintained and reviewed regularly.

8.3 Your Role in Account Security

While 1111bte takes robust measures to protect your data on our side, account security is a shared responsibility. We strongly recommend that you:

• Use a strong, unique password for your 1111bte account that you do not reuse on any other website.
• Never share your login credentials, including username and password, with any other person.
• Log out of your account when using a shared or public device.
• Contact support@1111bte immediately if you suspect unauthorised access to your account.
• Keep your registered email address and mobile number current so that account security alerts reach you promptly.

9.1 Changes to This Privacy Policy

1111bte reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. When changes are material — meaning they affect your rights or the way we use your data in a significant way — we will notify you by email to your registered address at least 7 days before the changes take effect. Non-material changes (such as typographic corrections, clarification of existing practices, or formatting updates) may be made without advance notice.

The "last reviewed" date at the top of this policy and in the last-updated bar will always reflect the most recent revision. We encourage you to review this policy periodically — particularly after receiving a change notification — to stay informed about how your data is protected.

Your continued use of the 1111bte Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you must stop using the Platform and may request account closure by contacting support@1111bte.

9.2 Cross-Border Data Considerations

1111bte primarily serves players located in Bangladesh, and the majority of our data processing occurs within secure data centres serving the South Asia region. In limited circumstances — for example, when using international KYC verification or fraud prevention services — personal data may be processed by partners located outside Bangladesh. In all such cases, we require contractual data protection commitments from those partners that are at least as protective as the standards set out in this Privacy Policy.

9.3 Links to Third-Party Sites

The 1111bte Platform may contain links to game providers' promotional pages or other third-party resources. These third-party websites operate independently of 1111bte and are governed by their own privacy policies. 1111bte is not responsible for the privacy practices of any third-party site and recommends that you review the privacy policy of any external site you visit.

9.4 Contact for Privacy Matters

For all privacy-related enquiries, data rights requests, complaints, or questions about this Privacy Policy, please contact the 1111bte data protection team at: