SX111 Privacy Policy – How We Protect Your Data in Pakistan

This Privacy Policy ("Policy") is published by SX111 ("the Company," "we," "us," "our") and applies to all users of the sx111.app platform — including Pakistani players who access the website through a desktop browser, mobile browser or the SX111 mobile application.

At SX111 we operate on the principle that your personal information belongs to you. We collect only what we genuinely need to provide you with a safe, compliant and functional betting experience. We do not sell your data. We do not share it for third-party marketing. And we work hard to keep everything you share with us secure.

This Policy covers all personal data that SX111 collects, processes and stores in connection with your account. It also explains the rights you have over your own data and how to exercise them. The Policy should be read alongside our Terms and Conditions, which form the overall agreement governing your use of SX111.

If you have any questions about this Policy that are not answered here, contact us at any time via live chat from within your SX111 account or by email at support@sx111.app. We will respond in plain language — no legal jargon, no deflection.

SX111 collects personal data in several categories depending on how you interact with the platform. Below is a full breakdown of every category of personal information that SX111 may hold:

Identity and Contact Information

• Full legal name as it appears on your CNIC or other government-issued identity document
• Date of birth (used for mandatory age verification)
• CNIC number (collected as part of the Pakistani identity verification process required for withdrawals)
• Pakistani mobile phone number (used for account setup and communication)
• Email address, if provided
• Residential address in Pakistan (required for regulatory compliance on larger accounts)

Financial Information

• Registered mobile wallet account details (Easypaisa, JazzCash, NayaPay or SadaPay account numbers — in your own name only)
• Bank account details for IBFT transfers (account title and IBAN)
• Debit or credit card details, processed securely through our certified payment gateway (SX111 does not store full card numbers)
• Transaction history: deposits, withdrawals, bonus credits and their dates and amounts in PKR

Betting and Gaming Activity

• Complete betting history across all products: sports, poker, virtual sports
• Stake amounts, odds taken, markets selected and outcomes
• Poker hand histories and tournament participation records
• Bonus and promotion participation history

Technical and Device Data

• IP address at time of registration and at subsequent logins
• Device type, operating system and browser information
• Session start and end times
• Cookies and similar tracking technology data (see Section 7 for full details)
• Approximate geolocation based on IP address (not GPS location)

Communication Records

• Live chat transcripts with the SX111 support team
• Emails sent to and received from support@sx111.app
• Records of responsible gaming tool usage (e.g., when you set a deposit limit or cool-off period)

SX111 collects personal data through three primary channels:

Directly from you: When you register an account, complete identity verification, make a deposit or withdrawal, contact our support team or participate in a promotion, you provide personal data to us directly. This is the largest source of personal data SX111 holds.

Automatically during platform use: When you browse sx111.app, place bets or play poker, our platform automatically records technical data including your IP address, device specifications, session duration and navigation patterns. This data is collected via server logs and cookies — see Section 7 for details on our cookie policy.

From third-party verification services: To comply with our licensing obligations and anti-money laundering requirements, SX111 uses third-party identity verification services that may cross-reference the details you provide against public records and identity databases. These services confirm that your identity information is genuine. SX111 does not retain raw data from these checks beyond what is needed for compliance records.

SX111 only uses your personal data for purposes that are necessary, proportionate and clearly explained. The table below maps each category of data we collect to the specific purpose it serves:

SX111 does not use your personal data to build profiles for sale to advertisers. We do not use your betting history to make automated decisions about your creditworthiness or insurance risk. Any automated processing we conduct — such as fraud scoring — is reviewed by a human team member before any significant action is taken against an account.

SX111 does not sell, rent or trade your personal data to any third party for marketing or commercial purposes. Full stop. The categories of third parties who may receive limited personal data from SX111 are listed below, along with the specific reason for each disclosure:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, IBFT bank networks and card payment gateways receive the transaction data necessary to process your specific deposit or withdrawal request. These providers are contractually bound to use your data only for transaction processing.
• Identity verification services: Third-party KYC and AML screening providers receive your name, date of birth and CNIC number for the purpose of identity verification. These providers operate under data processing agreements that restrict their use of your data to verification purposes only.
• Regulatory authorities: If required by our gaming licence or by applicable law, SX111 may be legally obligated to disclose player records to the relevant regulatory or law enforcement authority. We will always seek to notify you of such a disclosure unless legally prohibited from doing so.
• Platform technology providers: Our core platform infrastructure providers — including cloud hosting, cybersecurity and customer support software — may process certain technical data as part of delivering services to SX111. These providers are carefully selected and operate under strict data processing agreements.
• Fraud prevention networks: Anonymised or pseudonymised data may be shared with industry fraud prevention databases to detect and prevent financial crime. No identifiable personal data is shared for this purpose without legal justification.

SX111 is specifically designed for Pakistani payment methods — Easypaisa, JazzCash, NayaPay, SadaPay, IBFT bank transfers and Visa/Mastercard cards. Because all transactions are in PKR, your financial data never leaves the Pakistani payment ecosystem unnecessarily.

All payment data transmitted between your device and the SX111 platform is encrypted using TLS (Transport Layer Security) encryption. SX111 does not store full debit or credit card numbers on our servers — card transactions are tokenised by our certified payment gateway, which is PCI-DSS compliant.

For mobile wallet transactions (Easypaisa, JazzCash, NayaPay, SadaPay), SX111 records the wallet account number and transaction reference for the purpose of matching your deposit to your account and processing your withdrawal to the correct destination. This record is retained for the period required by our regulatory obligations and then purged.

SX111 will never ask you to share your Easypaisa or JazzCash PIN with us. Your mobile wallet PIN is your own — we only need the registered phone number associated with your wallet account. If you receive any communication asking for your mobile wallet PIN and claiming to be from SX111, treat it as fraudulent and report it to us immediately.

SX111 uses cookies and similar tracking technologies on the sx111.app website. A cookie is a small text file placed on your device when you visit a website. Here is exactly how we use them:

• Strictly necessary cookies: These are required for the SX111 platform to function. They maintain your login session, remember your bet slip contents and ensure secure transactions. You cannot opt out of these cookies while using the platform — they are essential to the service.
• Functional cookies: These remember your preferences — such as your preferred language, display settings and the last sport you were viewing. They make your SX111 experience more convenient but are not essential. You can disable them without losing core platform functionality.
• Analytics cookies: These help SX111 understand how Pakistani players use the platform — which pages are most visited, where users drop off and which features are most popular. This data is aggregated and anonymous. We use this to improve the platform for the entire SX111 community.
• Session cookies: These expire when you close your browser and are used to manage your active session on the SX111 platform securely.

SX111 does not use third-party advertising cookies or tracking pixels for commercial advertising purposes. We do not participate in cross-site tracking networks that follow users across the internet.

You can manage your cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent the SX111 platform from functioning correctly. For all other cookie types, you can adjust your browser settings to block or delete them at any time.

SX111 retains personal data for as long as it is needed for the purpose for which it was collected, or for as long as required by our regulatory obligations. The specific retention periods for key data categories are as follows:

• Active account data: Retained for the duration of your account plus a minimum of 5 years after account closure, as required by our anti-money laundering and gaming licence obligations.
• Transaction records: Retained for a minimum of 7 years after each transaction, as required by financial regulations.
• CNIC and identity verification records: Retained for the duration of your account and for 5 years after account closure.
• Betting history: Retained for the duration of your account. After account closure, betting history is retained in anonymised form for analytical purposes only.
• Support communications: Retained for 3 years from the date of the communication or the resolution of any associated complaint.
• Marketing consent records: Retained until you withdraw consent plus 3 years, to demonstrate compliance with consent requirements.

After the applicable retention period has elapsed, SX111 will securely delete or anonymise your personal data so that it can no longer be linked to you as an individual.

SX111 invests significantly in data security. The following technical and organisational measures are in place to protect your personal information:

• TLS encryption: All data transmitted between your device and the SX111 platform is encrypted using industry-standard TLS 1.2 or higher. The padlock icon in your browser confirms this connection is active.
• Data encryption at rest: Sensitive personal data — including CNIC details, payment information and identity verification records — is encrypted in SX111's databases using AES-256 encryption.
• Access controls: Only authorised SX111 staff members with a specific operational need can access personal player data. Access is logged, audited and reviewed regularly. No third-party vendor has unrestricted access to player data.
• Two-factor authentication: Available on all SX111 player accounts. We strongly recommend enabling 2FA to add a second layer of security to your login.
• Penetration testing: The SX111 platform undergoes regular security penetration tests by independent cybersecurity professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident response: SX111 maintains a documented data breach response procedure. In the event of a data breach that affects your personal information, we will notify you and the relevant regulatory authority within the timeframe required by applicable law.

You have meaningful rights over your personal data at SX111. These are not theoretical rights buried in the small print — they are practical options you can exercise by contacting our support team. Here is what you can ask for:

SX111 is strictly for adults aged 18 and over. The platform does not knowingly collect personal data from anyone under 18 years of age. If you are under 18, you must not register an account, provide any personal information or attempt to access any betting or gaming product on the SX111 platform.

SX111 uses mandatory age verification during the account registration process. All players must confirm that they are 18 or older, and full withdrawal access requires CNIC verification that confirms the account holder's date of birth. Where SX111 has reason to believe an account may be operated by a minor — based on any available data — the account will be immediately suspended pending investigation.

If you are a parent or guardian and believe that a person under 18 in your household has registered an account at sx111 using false details, please contact us immediately at support@sx111.app. We will act promptly to close the account and return any deposited real-money balance after verifying the circumstances.

We also encourage parents and guardians to use parental control software to restrict access to online betting and gaming platforms on devices shared with children. SX111 supports the use of such tools as part of our overall commitment to protecting minors.

SX111 may send you promotional communications — including information about new features, bonus offers, upcoming tournaments and special promotions — if you have consented to receive marketing at the time of registration or subsequently through your account settings.

Marketing communications from SX111 will be sent via SMS to your registered Pakistani mobile number or via email if you provided one. We will only ever send marketing communications under the SX111 brand — if you receive promotional messages claiming to be from sx111 from an unrecognised sender number or email address, treat them as suspicious and report them to us.

You can opt out of marketing communications at any time through any of the following methods:

• Updating your communication preferences in the Account Settings section of your SX111 dashboard.
• Replying STOP to any SMS marketing message from SX111.
• Contacting support@sx111.app and requesting removal from all marketing lists.

Opting out of marketing communications does not affect your ability to use the SX111 platform or receive transactional communications that are necessary for your account — such as deposit confirmations, withdrawal notifications and security alerts. These functional communications cannot be opted out of while your account is active, as they form part of the essential service SX111 provides.

SX111 will not send marketing to any player who has activated a self-exclusion or has otherwise indicated through our responsible gaming tools that they wish to reduce their betting activity.

SX111 reviews this Privacy Policy regularly and may update it to reflect changes in our data practices, applicable law or platform functionality. When material changes are made to how we collect or use your personal data, SX111 will notify registered Pakistani players by SMS or via an in-platform notification at least 14 days before the changes take effect.

Minor clarifications or formatting updates that do not change the substance of how SX111 handles your data may be made without prior notice. The "Last Updated" date at the top of this page always reflects the most recent version.

Your continued use of the SX111 platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you disagree with any changes, you should stop using the platform and contact support to discuss your options.

For any question, request or complaint related to your personal data and how SX111 handles it, contact us through any of the following channels:

• Live Chat: Available 24/7 from within your logged-in SX111 account. For data-related requests, use the live chat and specifically mention "Privacy Request" so the query is routed to the right team.
• Email: support@sx111.app — include your registered mobile number and the nature of your request. Data access, correction or deletion requests submitted by email will receive a written response within 30 days.

SX111 is committed to responding to all data-related requests promptly and in plain language. We will not direct you to a generic FAQ page or provide a boilerplate response — every request receives individual attention from someone who has actually reviewed your account.