kd111 Privacy Policy & Data Protection

kd111 is committed to protecting the privacy and personal data of every individual who interacts with our platform. This Privacy Policy applies to all users of kd111, including registered players, visitors who browse the platform without a registered account, and individuals who contact our support team. It governs all personal data collected through the kd111 website, mobile interface, and any other access channel made available by the platform.

This Policy is written in the English language and is designed to be clear, transparent, and accessible to our player base across Bangladesh, including players in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar. In the event of any conflict between this English version and any translated or summarised version, the English text shall prevail.

kd111 recognises that responsible data handling is inseparable from responsible gambling. We process personal data only to the extent strictly necessary to deliver our services, comply with our legal obligations, protect the security of our platform, and prevent fraud and financial crime. We do not sell your personal data to third-party advertisers or data brokers under any circumstances.

For the purposes of this Privacy Policy, the data controller — the entity responsible for determining the purposes and means of processing your personal data — is kd111, operating the platform at kd111.io. All data subject rights requests, privacy-related complaints, and data protection enquiries should be directed to the kd111 Data Protection contact, reachable via the email address listed in Section 14 of this Policy.

kd111 has designated an internal data protection focal point who is responsible for overseeing compliance with this Policy, monitoring data handling practices across all platform operations, and acting as the primary point of contact for regulatory enquiries and player rights requests. All such communications are handled in strict confidence and with appropriate urgency.

kd111 collects personal data that falls into the following principal categories. The specific data points collected from any individual player will depend on the nature of their interaction with the platform — for example, a visitor who browses without registering will have less data collected than a registered player who has completed KYC verification and made transactions.

kd111 collects personal data through several distinct channels, each of which is described below. In every case, data collection is limited to what is necessary for the stated purpose.

• Direct submission by you: When you register an account, complete your KYC verification, make a deposit or withdrawal, contact our support team, or update your account profile, you provide data directly to kd111.
• Automated technical collection: When you access the kd111 platform, our servers automatically collect technical data including your IP address, device identifiers, browser fingerprint, session timing, and page interaction data. This collection occurs whether or not you are logged in to a registered account.
• Cookies and tracking technologies: kd111 uses cookies, web beacons, and similar technologies to maintain session state, remember your preferences, and analyse platform usage. Full details are provided in Section 8 of this Policy.
• Payment providers: When you conduct a transaction using bKash, Nagad, Rocket, Upay, Visa, or Mastercard, the relevant payment provider shares transaction confirmation data with kd111 to allow us to credit or debit your account balance correctly.
• Identity verification providers: kd111 may use third-party identity verification services to cross-check the documents you submit during KYC. These services return a verification status to kd111 but do not retain copies of your documents beyond the verification transaction.
• Fraud prevention and AML screening: kd111 may receive data from licensed fraud detection and anti-money-laundering screening services in the course of assessing transactions and player activity for risk.

kd111 processes personal data only where a lawful basis for processing exists. The primary lawful bases on which kd111 relies are: (a) the performance of a contract with you (i.e., your account agreement with kd111); (b) compliance with legal obligations to which kd111 is subject; (c) your explicit consent where required; and (d) the legitimate interests of kd111, where those interests are not overridden by your rights and freedoms.

kd111 retains personal data for only as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following retention principles apply across the principal data categories:

• Active account data: Retained for the duration of your account's active status, plus a minimum of five years following account closure, in order to satisfy anti-money-laundering record-keeping obligations.
• KYC and identity documents: Retained for a minimum of five years from the date of submission or from the date of account closure, whichever is later, in accordance with AML compliance requirements.
• Financial transaction records: Retained for a minimum of five years from the date of each transaction, consistent with financial record-keeping obligations.
• Gameplay and betting records: Retained for a minimum of three years from the date of each recorded session or wager, for dispute resolution and responsible gaming monitoring purposes.
• Support communications: Retained for two years from the date of the final interaction in a support thread, unless the communication relates to a formal dispute or complaint, in which case retention follows the dispute resolution timeline plus one year.
• Technical and session data (logs): Retained for 12 months from the date of collection, after which they are aggregated or deleted.
• Marketing consent records: Retained for the duration of your consent plus two years, to maintain an auditable record of consent status.

Upon expiry of the applicable retention period, kd111 will securely delete or anonymise personal data in accordance with our internal data disposal procedures. Anonymised data — from which no individual can be identified — may be retained indefinitely for analytical and statistical purposes.

kd111 does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Personal data is shared only in the limited circumstances described below, and only to the extent necessary for the relevant purpose.

• Payment service providers: bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive the minimum transactional data required to process your deposits and withdrawals. These providers operate under their own privacy policies and data protection frameworks.
• Identity verification services: Third-party KYC providers receive copies of your identity documents and return a verification result. They are contractually bound to process this data solely for verification purposes and not to retain or further process it.
• Fraud and AML screening services: Licensed fraud prevention and AML monitoring providers may receive transaction data and identity details for risk screening. These providers operate under strict confidentiality and legal compliance obligations.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other game providers receive session and gameplay data necessary to deliver the game experience. They do not receive your identity or financial data unless required for their own regulatory compliance.
• Legal and regulatory authorities: kd111 will disclose personal data to competent legal, regulatory, or law enforcement authorities where required to do so by applicable law, court order, or where kd111 has a good-faith belief that disclosure is necessary to prevent or investigate fraud, money laundering, or other criminal activity.
• Corporate transactions: In the event of a merger, acquisition, or transfer of kd111's business, personal data may be transferred to the acquiring entity as part of the transaction. Affected players will be notified in advance of any such transfer.

kd111 uses cookies and similar tracking technologies to enable core platform functionality, maintain session security, and improve the user experience. A cookie is a small text file placed on your device by the kd111 platform when you visit. Cookies do not contain executable code and cannot be used to access other data on your device.

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences such as language settings, recently played games, and display preferences. Disabling these cookies will not prevent platform use but may reduce personalisation.
• Performance and Analytics Cookies: Collect anonymised or pseudonymised data about how players use the platform — which pages are visited most frequently, session duration, and error rates. This data is used to improve the platform. kd111 uses only first-party analytics tools; player data from these cookies is not shared with third-party advertising networks.
• Security Cookies: Used for fraud detection, abuse prevention, and login security verification. These include cookies that record device fingerprint components to detect suspicious or anomalous login behaviour.

You may manage or disable non-essential cookies through your browser's privacy settings. Please note that disabling functional or performance cookies may affect the quality of your platform experience. kd111 does not use third-party advertising cookies or retargeting pixels on our platform.

kd111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security programme is reviewed and updated on a regular basis to address evolving threats and to reflect industry best practice.

• SSL/TLS Encryption: All data transmitted between your device and the kd111 platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Look for the padlock indicator in your browser's address bar when using kd111.
• Data Encryption at Rest: Sensitive data fields — including identity document data, financial account details, and password credentials — are encrypted using AES-256 or equivalent encryption standards in our database storage systems.
• Access Controls: Access to personal data within kd111's internal systems is restricted on a strictly need-to-know basis. Staff access is controlled by role-based permissions, and all internal data access events are logged and auditable.
• Password Security: Player passwords are stored as salted cryptographic hashes. kd111 staff members cannot view your plain-text password. If you forget your password, it must be reset via the account recovery process — it cannot be retrieved.
• Two-Factor Authentication (2FA): kd111 offers optional SMS-based two-factor authentication for all registered accounts. Players are strongly encouraged to enable 2FA as an additional layer of account security.
• Fraud Monitoring: kd111 operates continuous automated monitoring for suspicious login patterns, unusual transaction behaviour, and other indicators of account compromise or fraudulent activity.
• Data Breach Response: In the event of a personal data breach that poses a risk to affected individuals, kd111 will notify relevant authorities and the affected players in accordance with applicable data protection obligations and within the timeframes required by law.

As an individual whose personal data is processed by kd111, you hold a set of data subject rights. kd111 is committed to honouring these rights promptly and in full. To exercise any of the rights listed below, please contact our data protection focal point via the contact details in Section 14. We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days, or notify you if an extension is required for complex requests.

• Right of Access: You have the right to request a copy of the personal data kd111 holds about you, together with information about how it is being processed. This is commonly known as a Subject Access Request (SAR).
• Right to Rectification: If any personal data kd111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. For many data fields (such as contact details), you can update these directly in your account profile.
• Right to Erasure ("Right to Be Forgotten"): You may request that kd111 delete your personal data. This right applies where the data is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other lawful basis exists. Note that this right is subject to kd111's legal obligations — for example, financial transaction records and KYC documents must be retained for the periods specified in Section 6, and erasure requests for this data will not be fulfilled during the mandatory retention period.
• Right to Restrict Processing: In certain circumstances, you may request that kd111 temporarily restrict the processing of your data — for example, while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where processing is based on your consent or a contract and is carried out by automated means, you may request that kd111 provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on kd111's legitimate interests, including profiling for fraud prevention. You also have an absolute right to object to direct marketing at any time, including profiling for marketing purposes.
• Right to Withdraw Consent: Where kd111 relies on your consent as the lawful basis for processing (for example, sending promotional communications), you may withdraw that consent at any time by contacting support or updating your communication preferences in your account settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

The kd111 platform is strictly intended for adults aged 21 years and above. kd111 does not knowingly collect, process, or retain personal data relating to individuals under the age of 21. Account registration by persons under 21 is prohibited under kd111's Terms & Conditions, and any account found to belong to a minor will be immediately closed and all associated data deleted, subject only to mandatory legal record-keeping obligations.

If you are a parent or guardian and you have reason to believe that a person under the age of 21 has registered an account on kd111 or has provided personal data to the platform, please contact us immediately at [email protected]. kd111 will investigate the matter promptly and take the appropriate action, including closing the account and erasing the data where permitted by law.

The kd111 platform may contain references to third-party game providers and payment partners whose services are integrated into the platform. While kd111 takes care to work only with reputable and compliant partners, these third parties operate under their own privacy policies and data protection frameworks. kd111 is not responsible for the privacy practices of third-party providers, and we encourage you to review the privacy documentation of any third-party service with which you interact directly.

kd111 does not include advertising links to external websites or embed third-party tracking scripts from advertising networks on the platform. Any integration with a third-party service is limited to what is strictly necessary for the delivery of the kd111 platform's core functionality.

kd111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform operations. When material changes are made, kd111 will notify registered players via email and/or a prominent notice on the platform at least 7 days prior to the changes taking effect. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision.

For minor or non-material changes — such as corrections of typographical errors, clarifications that do not alter the substance of the Policy, or updates to contact information — kd111 may update this Policy without advance notice, although the revised date will still be updated accordingly. We recommend that all registered players review this Privacy Policy periodically to remain informed of how kd111 manages their personal data.

Continued use of the kd111 platform following the effective date of any update to this Policy constitutes your acceptance of the revised terms. If you do not agree with any updated version of this Policy, you should discontinue use of the platform and contact our support team to request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way kd111 processes your personal data, please contact our data protection focal point using the details below. All enquiries are treated with strict confidentiality and will receive a substantive response within 30 calendar days.

If you are not satisfied with kd111's response to your privacy enquiry or data subject rights request, you have the right to escalate your complaint to the relevant data protection or consumer rights authority in your jurisdiction. kd111 will cooperate fully with any investigation by a competent authority and will implement any remedial measures required as a result of such investigation.

For responsible gaming concerns — including requests to set deposit limits, activate cooling-off periods, or self-exclude — please visit the Responsible Gaming page or contact our 24/7 support team directly. These requests are handled with the highest priority and are processed without delay.