d111 Privacy Policy

Who We Are

d111 ("d111", "we", "us", "our") operates the online casino and sports betting platform accessible at d111.asia (the "Platform"). We are the data controller responsible for the personal information collected through the Platform, which means we determine the purposes and means by which personal data is processed.

Our primary audience is adult players aged 21 and above located in Bangladesh. All personal data processing described in this Privacy Policy relates to individuals who register an account, use the Platform's products and services, or interact with our customer support team.

This Privacy Policy applies exclusively to data processed through the d111 Platform. It does not govern the privacy practices of third-party game providers, payment processors, or any other external services you may interact with independently of d111.

Data We Collect

d111 collects personal data from you directly when you register an account, use the Platform, contact customer support, or participate in promotions. We also collect certain data automatically when you access the Platform. The categories of personal data we process are set out below.

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identity document
• Date of birth (used solely for age verification purposes)
• Bangladesh mobile phone number (used for account authentication and communications)
• Email address (if provided during registration or KYC)
• Residential address in Bangladesh (collected during KYC verification)

2.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents, including National Identity Card (NID), passport, or driving licence
• Proof of mobile wallet ownership (bKash, Nagad, Rocket, or Upay account confirmation)
• Selfie or facial image where required for liveness verification

2.3 Financial & Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method identifiers (mobile wallet numbers, masked card numbers) — full card numbers are never stored by d111
• Transaction reference numbers issued by payment processors
• Account balance history and bonus credit records

2.4 Gameplay & Betting Data

• Game session logs, including game titles played, bet amounts, and outcomes
• Sports bet selections, markets, odds accepted, and settlement results
• Responsible gaming tool settings, including deposit limits, session time limits, and self-exclusion status

2.5 Technical & Device Data

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser type and version
• Session timestamps, login history, and session duration
• Cookies and similar tracking technologies (see Section 6)

2.6 Communications Data

• Records of communications between you and d111 customer support, including chat transcripts and email correspondence
• Feedback, complaints, and dispute records

How We Use Your Data

d111 uses the personal data it collects exclusively for the purposes listed below. We do not use your data for any purpose that is incompatible with the reason it was originally collected.

d111 does not use your personal data to build profiles for sale to third parties, to deliver third-party advertising unrelated to d111, or for any automated decision-making that produces legal or similarly significant effects without human oversight.

Legal Basis for Processing

d111 processes your personal data on the following legal bases, depending on the specific purpose for which the data is used:

• Contractual necessity: Processing that is required to fulfil our obligations to you under the d111 Terms & Conditions — including account management, KYC verification, transaction processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, age verification requirements, and cooperation with law enforcement authorities.
• Legitimate interests: Processing carried out to pursue the legitimate interests of d111, including fraud detection, platform security, responsible gaming monitoring, and improving the Platform — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing that is based on your freely given, specific, and informed consent — primarily for optional marketing communications and promotional personalisation. You may withdraw consent at any time by contacting [email protected], without affecting the lawfulness of processing carried out before your withdrawal.

Sharing Your Data

d111 does not sell your personal data. We share personal data with third parties only in the circumstances described below, and only to the extent strictly necessary for each purpose.

5.1 Licensed Game Providers

d111 integrates games from licensed third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may receive limited technical session data (such as anonymised player identifiers and bet amounts) to facilitate game delivery, fairness certification, and RNG auditing. Game providers are contractually prohibited from using session data for any purpose beyond game operation.

5.2 Payment Processors

To process deposits and withdrawals, d111 shares the minimum necessary financial and identity data with approved payment partners including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and card network processors (Visa and Mastercard). All payment processors are required to maintain data security standards commensurate with their role as financial service providers.

5.3 Identity Verification Services

d111 may engage third-party KYC and identity verification providers to assist with document verification and fraud screening. These providers receive only the identity data required for verification and are bound by strict data processing agreements.

5.4 Legal and Regulatory Authorities

d111 will disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law, pursuant to a lawful order, or where disclosure is necessary to protect the legal rights or safety of d111, its employees, or its users.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or a material part of d111's business assets, personal data held by d111 may be transferred to the acquiring entity as part of that transaction. Affected users will be notified of any such transfer and any change to data controller identity before the transfer takes effect.

Cookies & Tracking Technologies

d111 uses cookies and similar client-side tracking technologies to operate core platform functions, maintain session state, prevent fraud, and analyse aggregate usage patterns. The categories of cookies used by d111 are described below.

Strictly Necessary Cookies

These cookies are essential for the Platform to function. They manage your login session, maintain your account authentication state, and preserve your responsible gaming settings. Strictly necessary cookies cannot be disabled without impairing your ability to use the Platform.

Performance & Analytics Cookies

These cookies collect anonymised information about how players navigate the Platform — including which pages are visited most frequently and where users encounter errors. This data is used exclusively to improve Platform performance and user experience. No personally identifiable information is collected through analytics cookies.

Functional Cookies

Functional cookies remember your preferences (such as language selection and display settings) so that you do not need to re-configure them on each visit. They do not track your activity across third-party websites.

Managing Your Cookie Preferences

You may configure your browser to block or delete cookies at any time. Please note that blocking strictly necessary cookies will prevent you from logging in to your d111 account. Detailed instructions for managing cookies are available in the help documentation of your browser. d111 does not currently respond to Do Not Track (DNT) browser signals, as no universally accepted DNT standard has been established.

Data Retention

d111 retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, or for such longer periods as are required or permitted by applicable law. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is either permanently and securely deleted from d111 systems or anonymised such that it can no longer be linked to any identifiable individual. Anonymised aggregate data may be retained indefinitely for statistical analysis and platform improvement.

Security Measures

d111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our current security framework includes the following controls:

• Transport encryption: All data transmitted between your device and d111 servers is encrypted using TLS 1.2 or higher (256-bit SSL). Secure connections are enforced on all Platform endpoints.
• Data at rest encryption: Sensitive personal data, including identity documents and financial records, is encrypted at rest using AES-256 encryption on d111's server infrastructure.
• Access controls: Access to personal data within d111's internal systems is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Multi-factor authentication: Administrative access to d111's data processing systems requires multi-factor authentication. Players are strongly encouraged to enable available account security features.
• Regular security audits: d111's server infrastructure and data handling practices are subject to regular internal reviews and periodic independent security assessments.
• Incident response: d111 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to the rights and freedoms of affected individuals, d111 will notify affected users without undue delay.

While d111 takes all reasonable precautions to secure your data, no internet-based transmission or electronic storage system is completely immune to risk. Players are strongly advised to protect their own d111 login credentials and to notify d111 immediately at [email protected] if they suspect any unauthorised access to their account.

Your Rights

As a d111 account holder whose personal data we process, you have the following rights with respect to that data. To exercise any of these rights, please contact us at [email protected]. We will respond to all requests within 30 days of receipt, and we will not charge a fee for handling reasonable requests.

• Right of access: You have the right to request confirmation of whether d111 holds personal data about you, and to receive a copy of that data in a readable format.
• Right to rectification: You have the right to request correction of any personal data about you that is inaccurate or incomplete. Certain data corrections — such as changes to your registered name — may require supporting documentation.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other lawful basis for processing applies. This right does not apply where retention is required by law, including AML and financial record-keeping obligations.
• Right to restriction of processing: You have the right to request that d111 restrict its processing of your personal data in specified circumstances — for example, while a rectification request is under review.
• Right to data portability: You have the right to receive personal data you have provided to d111 in a structured, commonly used, machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to object: You have the right to object to processing of your personal data carried out on the basis of legitimate interests. d111 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, or where processing is necessary for legal claims.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

Children & Minors

The d111 Platform is strictly for adults aged 21 years and above. d111 does not knowingly collect personal data from individuals under the age of 21. If d111 becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, all personal data associated with the underage registration will be deleted or isolated pending investigation, and any deposits will be returned at d111's discretion in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor in your care has registered a d111 account, please contact d111 immediately at [email protected] so that the matter can be investigated and resolved without delay.

International Data Transfers

d111's primary server infrastructure is operated to serve the Bangladesh market. However, certain third-party service providers engaged by d111 — including licensed game studios (such as Pragmatic Play, Evolution Gaming, and NetEnt) and payment technology providers — may process data from servers located outside of Bangladesh.

Where personal data is transferred to a third country or international organisation, d111 ensures that appropriate safeguards are in place to maintain a level of data protection equivalent to that described in this Privacy Policy. These safeguards may include contractual obligations imposed on the recipient party through data processing agreements that require the maintenance of appropriate technical and organisational security measures.

By registering a d111 account and accepting the Terms & Conditions, you acknowledge that your personal data may be transferred to and processed in countries outside of Bangladesh as described in this section, subject to the protections outlined above.

Policy Changes & Contact

Changes to This Privacy Policy

d111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When we make a material change, we will notify registered account holders via the Platform or by email to the address on file, in advance of the change taking effect. The effective date at the top of this Privacy Policy will be updated to reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically. Your continued use of the d111 Platform following any amendment constitutes your acceptance of the updated Privacy Policy. If you do not accept any change, you must cease using the Platform and may request account closure by contacting our support team.

How to Contact Us

For all privacy-related matters — including data access requests, correction requests, deletion requests, complaints about our data handling practices, or general questions about this Privacy Policy — please contact the d111 data team at:

[email protected]
Available 24 hours a day, 7 days a week — Bangladesh Standard Time (BST, UTC+6)