Privacy Policy

This Privacy Policy ("Policy") describes how sx111 ("the Operator", "we", "us", "our") collects, processes, stores, shares and protects personal data in connection with your use of the sx111 platform at sx111.cam (the "Platform"), including all associated services, games, sports betting markets and customer support channels.

By registering an account, accessing the Platform or otherwise engaging with our services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the Platform.

This Policy should be read alongside our Terms & Conditions, which govern the overall use of the Platform, and our Responsible Gambling page, which describes the player-protection tools available to you.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, postal address, telephone number, date of birth, financial account details, IP address and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, transmission, combination, restriction, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, the Operator of the sx111 Platform.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller, under a contractual obligation and in accordance with the Controller's instructions.
• "KYC Data" means identity verification documentation and related personal data collected as part of the Know Your Customer process, including CNIC/passport copies and proof of address.
• "Cookies" means small text files placed on your device by the Platform for the purposes of session management, analytics and personalisation.
• "User", "you", "your" means any individual who accesses or uses the Platform, whether registered or unregistered.

sx111 collects personal data only to the extent necessary to provide its services, meet regulatory obligations and maintain Platform security. The categories of personal data we may collect are described in the table below:

We do not intentionally collect sensitive categories of personal data (such as health data, political opinions or religious beliefs) unless specifically required by a regulatory obligation or explicitly provided by the user in the context of a responsible-gambling self-assessment.

sx111 collects personal data through the following means:

• Direct Collection: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, set responsible-gambling limits or otherwise interact directly with the Platform's forms and interfaces.
• Automated Technical Collection: Through the use of cookies, web beacons, session logging and server-side analytics that automatically record technical and usage data as you navigate the Platform. See Section 9 (Cookies & Tracking) for further details.
• Payment Processors: When you initiate a transaction via a payment method (such as a bank transfer or e-wallet), the payment processor may pass to us your transaction confirmation reference, masked payment details and transaction timestamps required for reconciliation and compliance purposes.
• KYC & Fraud-Prevention Partners: We may receive supplementary identity verification data from third-party KYC service providers engaged to assist in compliance checks.
• Publicly Available Sources: In limited circumstances and for fraud-prevention purposes, we may cross-reference data against publicly available or commercially licensed data sources.

We process your personal data for the following specific purposes:

• Account Management: To register, maintain and administer your sx111 account, including authentication, account security and profile updates.
• Service Delivery: To provide access to games, sports betting markets (including cricket, PSL, ICC events, football and UFC), live casino tables and all other Platform features to which you are entitled as a registered user.
• Payment Processing: To process deposits and withdrawals via available payment methods, conduct transaction reconciliation and manage your account balance.
• KYC & AML Compliance: To verify your identity, confirm your age (18+ minimum), conduct ongoing AML monitoring and comply with applicable regulations governing gambling operations.
• Fraud Prevention & Security: To detect, investigate and prevent fraudulent transactions, bonus abuse, account takeovers and other forms of misconduct or illegal activity.
• Responsible Gambling: To administer the deposit limits, loss limits, session timers, cooling-off periods and self-exclusion settings you configure on your account, and to monitor for signs of problem gambling where required.
• Customer Support: To respond to your queries, process complaints and provide assistance in English and Urdu through live chat and email channels.
• Legal Obligations: To comply with applicable law, respond to lawful requests from regulatory authorities and maintain records as required by our licensing obligations.
• Platform Improvement: To analyse aggregated usage data in order to improve Platform design, navigation, game selection and overall user experience — particularly for Pakistani users accessing from cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.
• Marketing Communications: To send you promotional communications about bonuses, new features and relevant offers, where you have not opted out of such communications. See Section 11 regarding your right to unsubscribe.

Where data protection law requires a legal basis for the processing of personal data, sx111 relies on the following bases depending on the processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions, including account management, service delivery and payment processing.
• Legal Obligation: Processing required to comply with applicable AML, KYC, tax, licensing and regulatory obligations imposed on the Operator.
• Legitimate Interests: Processing carried out for the purposes of fraud prevention, Platform security, responsible gambling monitoring and analytics, where those interests are not overridden by your data protection rights.
• Consent: For non-essential cookies and direct marketing communications, where we rely on your opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

sx111 does not sell, rent or trade your personal data to third parties for commercial marketing purposes. We may share your data with third parties only in the circumstances described below:

• Payment Service Providers: We share transaction data with payment processors to facilitate deposits and withdrawals. Payment provider names referenced for Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are illustrative references for familiar local payment rails. Their inclusion does not imply endorsement of or affiliation with gambling activities on this Platform. Actual data-sharing relationships are determined by the payment methods active at the cashier.
• KYC & Identity Verification Partners: Third-party KYC service providers contracted to assist with identity and document verification as part of our AML compliance programme. These partners process data strictly as Data Processors under contractual data protection agreements.
• Game & Technology Providers: Game studios and sports data providers that supply games and betting markets accessible on the Platform may receive pseudonymised session data for game performance and integrity purposes.
• Regulatory Authorities: We may be required to disclose personal data to gaming regulators, financial intelligence units, law enforcement agencies or courts in response to lawful orders, legal process or regulatory demands.
• Fraud Prevention Networks: Aggregated or flagged account data may be shared with industry fraud prevention services to protect the Platform and its users from fraudulent activity.
• Corporate Transactions: In the event of a merger, acquisition, restructuring or sale of the Operator's business, personal data may be transferred to the successor entity, subject to the same data protection obligations as this Policy.

sx111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Active Accounts: Personal data associated with an active account is retained for the duration of the account's active status and for the period required by the Operator's licensing authority following account closure.
• KYC & AML Records: Identity verification documents, transaction records and related AML documentation are retained for a minimum period as required by the applicable anti-money laundering regulatory framework — typically five (5) years from the end of the customer relationship, or longer if required by specific regulatory order.
• Communications Records: Support conversations, complaints and correspondence are retained for a period sufficient to enable dispute resolution and regulatory review.
• Technical & Usage Data: Anonymised or aggregated analytics data may be retained indefinitely for platform improvement purposes. Identifiable technical data (such as IP logs) is retained for a shorter period consistent with security and fraud-prevention needs.
• Marketing Preferences: Records of your marketing opt-in and opt-out preferences are retained for as long as necessary to honour your choices and demonstrate compliance.

Where personal data is no longer required, it is securely deleted or anonymised in a manner that prevents re-identification.

The Platform uses cookies and similar tracking technologies to operate correctly, analyse usage patterns and personalise your experience. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for Platform functionality, including session management, authentication and security features. These cannot be disabled without impairing Platform operation.
• Performance & Analytics Cookies: Used to collect anonymised information about how users navigate the Platform — pages visited, time on page, error events and navigation paths. This data helps us improve the Platform's usability and performance.
• Functional Cookies: Store your preferences, such as language settings, game lobby view configuration and responsible-gambling reminder intervals, to personalise your sessions.
• Marketing & Targeting Cookies: Used with your consent to track cross-session interactions for the purpose of relevant promotional communications. You may opt out of marketing cookies at any time.

Most web browsers allow you to manage cookie settings through the browser's privacy or settings menu. Disabling certain cookies may affect Platform functionality. Your cookie preferences may be updated at any time via the Platform's cookie management interface.

As an internationally operated platform, sx111 may transfer personal data to servers, processors or partners located outside the country in which you reside. Such transfers may include data sent to jurisdictions whose data protection laws differ from those in your own country, including Pakistan.

Where personal data is transferred internationally, the Operator takes appropriate steps to ensure that the transfer is conducted under safeguards that provide an adequate level of protection, including contractual data processing agreements with Data Processors that impose equivalent data protection obligations.

Subject to applicable law and the legal bases on which we process your data, you may have the following rights with respect to your personal data held by sx111:

• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You can update basic account details directly through your account settings.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations — in particular, AML record-keeping requirements that mandate retention for a defined minimum period.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request a copy of your personal data in a commonly used, machine-readable format.
• Right to Restrict Processing: You may request that we restrict the processing of your data in defined circumstances, such as during the resolution of an accuracy dispute.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing communications. To unsubscribe from marketing emails, use the unsubscribe link in any promotional email or contact support directly.
• Right to Withdraw Consent: Where processing relies on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of these rights, please contact our Data Privacy team at: [email protected]. We will aim to respond within a reasonable period as required by applicable law. Some requests may be subject to identity verification before they can be actioned.

sx111 implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, loss, disclosure, alteration or destruction. These include:

• Transport Encryption: All data in transit between your device and our servers is encrypted using TLS/SSL (256-bit) protocols. The padlock icon in your browser confirms this encryption is active.
• Access Controls: Personal data is accessible only to authorised personnel who require it to perform their specific operational or compliance duties. Access is governed by role-based permissions and audit logging.
• Data Minimisation: We collect and retain only the data necessary for defined operational and compliance purposes. Unnecessary data is purged on a scheduled basis.
• Intrusion Detection: Server infrastructure is monitored for anomalous access patterns, known threat signatures and potential breach attempts.
• Incident Response: In the event of a confirmed data breach affecting your personal data in a manner likely to result in risk to your rights, we will notify affected users and relevant regulatory authorities as required by applicable law.

While we apply robust security measures, no digital platform can guarantee absolute security. Users are responsible for maintaining the confidentiality of their account credentials and should contact support immediately if they suspect unauthorised account access.

The Platform is strictly intended for adults. Persons under the age of 18 (or the higher minimum age required by the Operator's licensing jurisdiction) are not permitted to register an account, access games or place bets on sx111 under any circumstances.

We do not knowingly collect personal data from individuals under 18 years of age. Age verification is conducted as part of the KYC registration process. If we become aware that personal data has been collected from an individual under the minimum age, we will close the associated account and delete or anonymise the relevant data as expeditiously as possible.

If you are a parent or guardian and believe that a person under 18 has registered on the Platform, please contact us immediately at [email protected] so that we may take appropriate action.

sx111 provides content and services in English targeting Pakistani users. This Privacy Policy acknowledges the following Pakistan-specific context relevant to data handling:

• Applicable Law: This Policy is governed by the laws of the Operator's licensing jurisdiction. Pakistan does not currently have a comprehensive data protection law equivalent to the EU GDPR; however, the Operator applies data minimisation, purpose limitation and security principles as a matter of operational best practice.
• Payment Reference Data: References to Pakistani payment methods — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — appear on the Platform for contextual familiarity. Where a user's payment transaction data is processed through any such provider, that provider's own privacy policy and data-handling practices apply to the transaction-side data they process. sx111 is not responsible for third-party provider data practices.
• Geolocation: The Platform may collect country and city-level geolocation data (derived from IP address) to manage geographic access controls and ensure compliance with the Operator's licensing conditions. This may affect users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other Pakistani cities.
• Gambling Legality: The Operator does not claim Pakistani government authorisation for online gambling. Users are responsible for assessing the lawfulness of their use of the Platform under Pakistan's Prevention of Gambling Act 1977 and any other applicable local legislation. This Policy does not constitute legal advice.

sx111 reserves the right to update or amend this Privacy Policy at any time. Material changes — particularly those that affect the scope of data processing, the categories of third parties with whom data is shared, or your rights — will be communicated to registered users via email to the address on record or by a prominent notice on the Platform.

The "Last reviewed" date at the top of this page reflects when the Policy was most recently updated. Continued use of the Platform following the publication of a revised Policy constitutes acceptance of the updated terms.

We encourage you to review this Policy periodically to remain informed about how we handle your personal data. If you have concerns about any change, please contact us before continuing to use the Platform.

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the sx111 support and data privacy team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: "Data Privacy Request — [Your Account Username]"
• Live Chat: Available through the Platform as an operator-provided service. Response times vary.
• Languages: Support is available in both English and Urdu.

We aim to acknowledge all privacy-related requests within a reasonable timeframe and to provide a substantive response as required by applicable law. Some requests — particularly erasure requests — may be subject to identity verification and assessment against legal retention obligations before they can be actioned.