Privacy Policy

This Privacy Policy ("Policy") describes how y111 ("y111", "we", "us" or "our") collects, processes, stores, shares and protects personal data in connection with the online gaming platform operated at https://y111.cam (the "Platform").

This Policy applies to all users who access or interact with the Platform, including registered account holders, visitors who browse without registering and individuals who contact y111 through any available support channel.

By accessing or using the y111 Platform, you acknowledge that you have read and understood this Policy. If you do not agree with how we process your personal data as described herein, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference into the overall agreement between y111 and its users.

The following terms have specific meanings throughout this Policy:

• "Personal Data" — any information that identifies or could reasonably be used to identify a living individual, including but not limited to name, email address, CNIC number, IP address, device identifier and payment account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, transfer, disclosure, erasure or any combination thereof.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the y111 Platform, the Data Controller is the operator of https://y111.cam.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under contractual obligation.
• "Consent" — a freely given, specific, informed and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "KYC" — Know Your Customer; the identity verification process required for regulatory compliance.
• "AML" — Anti-Money Laundering; regulatory obligations relating to the prevention of financial crime.
• "Cookies" — small text files placed on your device by the Platform to enable functionality, security and analytics.

The Data Controller responsible for the personal data processed through the y111 Platform is the operator of https://y111.cam. y111 is not registered with, or regulated by, any Pakistani data-protection authority. The applicable data-protection framework is determined by the jurisdiction in which y111 is licensed to operate.

For all data-protection queries, access requests and complaints, please contact us at the details provided in Section 16 of this Policy. We aim to acknowledge data-related queries within 72 hours of receipt.

y111 collects personal data from several sources and in several categories, as described below.

4.1 Data You Provide Directly

When you register an account, use the Cashier, complete KYC verification or contact support, you provide data including:

• Full legal name as it appears on your identity document
• Date of birth and age verification documents
• Email address and, where provided, phone number
• Residential address
• Government-issued identity document details (e.g., CNIC number and copy)
• Payment method details — including mobile wallet account references (e.g., Easypaisa or JazzCash registered name) or bank account information (e.g., IBAN for HBL, UBL, Meezan Bank or Bank Alfalah accounts)
• Source of funds information where requested for AML compliance
• Support communication content (live chat transcripts, email correspondence)

4.2 Data Collected Automatically

When you access or interact with the Platform, we automatically collect technical and usage data including:

• IP address and approximate geographic location
• Device type, operating system and browser version
• Session timestamps, login history and navigation paths
• Game play data including bets placed, outcomes, session duration and game preferences
• Transaction data including deposit and withdrawal history
• Responsible-gambling tool usage (e.g., limit settings and self-exclusion history)

4.3 Data From Third Parties

We may receive limited personal data from third-party service providers in the course of operating the Platform, including:

• Identity verification results from KYC service providers
• Fraud-risk signals from payment processors
• Age verification confirmations from third-party age-check services
• Self-exclusion status from any applicable exclusion scheme database we are connected to under our licensing obligations

y111 processes your personal data under one or more of the following lawful bases:

• Contractual Necessity: Processing required to fulfil the agreement between you and y111 — including account creation, managing your balance, processing transactions and providing gaming services.
• Legal Obligation: Processing required to comply with KYC, AML and other regulatory requirements imposed on y111 under applicable licensing conditions.
• Legitimate Interests: Processing for the prevention of fraud, security monitoring, platform improvement, responsible-gambling compliance and internal analytics — where these interests are not overridden by your rights.
• Consent: Where we send optional marketing communications or use non-essential cookies, we rely on your explicit, opt-in consent, which you may withdraw at any time.

y111 uses the personal data it collects for the following specific purposes:

• Account Management: Creating, maintaining and securing your registered account, including authentication and password recovery.
• Transaction Processing: Processing deposits, withdrawals and bonus crediting. This includes passing necessary payment data to payment service providers to facilitate transactions.
• Identity Verification (KYC): Verifying your identity, age and eligibility to use the Platform in compliance with regulatory obligations.
• Fraud Prevention and Security: Detecting, investigating and preventing fraudulent activity, money laundering, multi-accounting and other prohibited conduct.
• Responsible Gambling Compliance: Monitoring gaming behaviour to identify risk patterns, enforcing self-exclusion requests, and prompting responsible-gambling tool usage where appropriate.
• Customer Support: Responding to your support queries, resolving disputes and maintaining a record of support interactions for quality and compliance purposes.
• Platform Analytics and Improvement: Understanding how users interact with the Platform to identify technical issues, improve user experience and optimise gaming content offerings.
• Legal and Regulatory Compliance: Meeting obligations under the licensing framework applicable to the operator, including record-keeping requirements and responding to lawful authority requests.
• Marketing Communications (consent-based): Sending promotional offers, platform updates and relevant gaming information to users who have opted in to receive such communications. You may opt out at any time.

y111 does not sell personal data to third parties. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Service Providers: Data necessary to process your deposit or withdrawal transaction is shared with the relevant payment processor (e.g., the service provider underlying your chosen payment method). This may include your name and payment reference. Payment provider names referenced on the Platform (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are shared only to the extent required to process your transaction — no gambling endorsement by these providers is implied.
• KYC and Identity Verification Providers: Identity documents and related data are shared with third-party KYC service providers who process them on our behalf under contractual data-processing agreements.
• Game and Platform Technology Providers: Anonymised or pseudonymised technical data may be shared with game providers and platform technology partners for performance and analytics purposes.
• Legal and Regulatory Authorities: y111 may disclose personal data to competent legal or regulatory authorities where required by law, court order or under the licensing obligations applicable to the operator.
• Self-Exclusion Scheme Operators: Where applicable under the operator's licensing conditions, self-exclusion data may be shared with exclusion scheme operators to enforce a Player's exclusion request across connected platforms.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of y111's business, personal data may be transferred to the acquiring entity, subject to equivalent data-protection obligations.

As an internationally accessible Platform, y111 may process or store personal data in jurisdictions outside Pakistan. The data-protection standards applicable to such processing are determined by the regulatory framework of the jurisdiction in which y111 is licensed.

Where personal data is transferred to a third-party service provider located in a different country, y111 ensures that appropriate safeguards are in place, such as contractual data-processing clauses or equivalent protections, to maintain the security and integrity of your data throughout the transfer.

Pakistani users should be aware that Pakistani data-protection law may differ from the data-protection framework applicable to y111, and that Pakistani regulatory bodies may have limited jurisdiction over data processing carried out outside Pakistan.

y111 uses cookies and similar tracking technologies to support Platform functionality, security and performance analysis. The following categories of cookies may be in use:

You can manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will affect Platform functionality. Disabling analytics or marketing cookies will not prevent you from using the Platform.

y111 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your account and for a defined period following account closure, as required by applicable licensing and AML regulations.
• KYC Documentation: Retained for the period mandated by the operator's licensing framework following the closure or verification event, typically a minimum of five years in standard AML compliance contexts.
• Transaction Records: Financial transaction records are retained for a minimum period to satisfy regulatory record-keeping obligations.
• Support Communications: Retained for quality assurance and dispute-resolution purposes for a reasonable period following the closure of the relevant support case.
• Analytics Data: Anonymised or aggregated analytics data may be retained indefinitely as it no longer constitutes personal data once anonymised.

Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised. You may request information about the retention period applicable to your data by contacting our support team.

y111 implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• HTTPS / TLS encryption for all data in transit between your device and the Platform.
• Encryption at rest for sensitive data fields including identity documents and payment references.
• Access controls limiting personal data access to authorised personnel with a demonstrated need.
• Regular security assessments and monitoring of Platform infrastructure.
• Incident response procedures to detect, contain and report data security breaches in a timely manner.

Whilst y111 takes reasonable precautions to protect your data, no internet-based system is completely immune to security risk. You are also responsible for protecting access to your account — use a strong, unique password and do not share your login credentials with anyone.

Subject to applicable law and the operator's regulatory obligations, you have the following rights in respect of the personal data y111 holds about you. To exercise any of these rights, please contact us using the details in Section 16.

• Right of Access: You may request a copy of the personal data y111 holds about you, along with information about how it is processed.
• Right to Rectification: If any personal data y111 holds about you is inaccurate or incomplete, you may request that it be corrected or updated.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. This right is subject to y111's legal and regulatory obligations — data held for KYC or AML compliance purposes may not be deletable on request during applicable retention periods.
• Right to Restrict Processing: In certain circumstances, you may request that y111 restrict the processing of your data (e.g., while a rectification request is under review).
• Right to Data Portability: Where processing is based on consent or contract and carried out automatically, you may request a copy of your data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications or non-essential cookies), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Object: You may object to processing based on legitimate interests where you believe your rights override y111's stated interests. Each objection will be assessed on its individual merits.

y111 will respond to data rights requests within a reasonable timeframe (typically 30 days). Complex requests may require additional time, in which case we will notify you of the expected completion date.

The y111 Platform is strictly for adults aged 18 years and over, or the higher minimum age required by the operator's licensing jurisdiction. y111 does not knowingly collect personal data from individuals below the applicable minimum age.

Age verification is a mandatory component of the KYC process. Where y111 discovers that personal data has been collected from a minor in breach of age eligibility requirements, the associated account will be immediately closed, any deposited funds will be returned via the original payment method, and the data will be deleted in accordance with our retention and deletion procedures.

y111 is an English-language platform designed with Pakistani users in mind. This section addresses specific considerations relevant to data processing in the Pakistani context.

14.1 Pakistani Regulatory Bodies. y111 is not registered with or regulated by the Personal Data Protection Bill framework currently under development in Pakistan, the Pakistan Telecommunication Authority (PTA) or any other Pakistani data or consumer authority. Your rights under this Policy are governed by the data-protection framework applicable to y111's licensing jurisdiction.

14.2 Payment Data References. Where you use payment methods familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — we process the minimum payment data necessary to facilitate your transaction. We do not store full payment account credentials beyond what is technically required for the transaction and any applicable regulatory record-keeping.

14.3 CNIC and Identity Documents. If you submit a copy of your Pakistani CNIC or any other government-issued identity document for KYC purposes, this data is processed and stored in accordance with Section 10 (Retention) and is not shared with third parties beyond what is described in Section 7.

14.4 No Local Government Authorisation. y111 does not claim that its data processing is authorised or endorsed by the Government of Pakistan, the SBP or any Pakistani ministry or provincial authority. This does not affect your rights under this Policy.

y111 reserves the right to amend this Privacy Policy at any time. Where amendments are material — for example, changes to the categories of data we collect, the purposes for which we process it or the third parties with whom we share it — we will notify registered users via email and/or a prominent notice on the Platform prior to the changes taking effect.

The "Last updated" date at the top of this Policy reflects the date of the most recent published version. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the updated Policy.

We recommend reviewing this Policy periodically and particularly before submitting any new personal data or agreeing to any new promotional offer.

For all privacy-related queries, data subject access requests, complaints or concerns, please contact y111 using the details below. Note that the email address is provided as plain text only — please copy it manually into your email client.

Please also see our related policies: Terms & Conditions and Responsible Gambling Policy.