ph111 Privacy Policy

ph111 collects personal information from players in Bangladesh to enable account registration, verify identity, process payments, deliver gaming services, and comply with applicable legal obligations. The categories of information we collect are described below.

Registration and Account Information

When you create a ph111 account, we collect the information you provide directly, including:

• Full legal name as it appears on your government-issued identity document.
• Date of birth (used to verify that you meet the minimum age requirement of 18 years).
• Residential address, including city (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, or Cox's Bazar).
• Email address and phone number for account communication and authentication.
• Username and encrypted password.

Identity Verification (KYC) Documents

To fulfil our Know Your Customer obligations and to prevent underage gambling, money laundering, and fraud, ph111 may request and retain copies of:

• National Identity Card (NID) or passport.
• Proof of address (utility bill, bank statement, or similar document issued within the past three months).
• Proof of payment method ownership (e.g., a screenshot of your bKash, Nagad, Rocket, or Upay account showing your registered name and mobile number).

Financial Transaction Data

ph111 records all deposit and withdrawal transactions made on your account, including the payment method used, transaction amounts in Bangladeshi Taka (৳), transaction timestamps, and reference numbers. We do not store full bank account numbers or full mobile financial service PINs; payment method authentication is handled by the respective payment providers.

Gaming and Betting Activity

We maintain a comprehensive record of all gaming activity on your account, including bets placed, games played, stakes, outcomes, bonus usage, and session durations. This data is used for account management, dispute resolution, responsible gaming monitoring, and fraud detection.

Technical and Device Data

When you access ph111, our servers automatically collect certain technical information, including your IP address, browser type and version, operating system, device model, referring URL, and pages visited within ph111.im. This information is used for security monitoring, platform optimisation, and analytics.

Communications

If you contact ph111 support via live chat, email, or any other channel, we retain records of those communications, including any attachments you provide, for the purpose of resolving your enquiry and maintaining service quality records.

ph111 uses the personal information we collect for the following specific purposes. We do not use your data for any purpose that is incompatible with the original reason for collection without first obtaining your consent or establishing an alternative lawful basis.

ph111 processes your personal data on the following legal grounds, depending on the specific purpose of the processing activity:

• Contractual Necessity: Processing that is required to perform the contract between you and ph111 — including account creation, payment processing, game delivery, and customer support — is carried out on the basis that it is necessary to fulfil our contractual obligations to you.
• Legal Obligation: Certain processing activities, particularly KYC verification, anti-money laundering record-keeping, and responses to regulatory enquiries, are required by applicable law. ph111 processes data for these purposes on the basis of legal obligation.
• Legitimate Interests: ph111 processes data for fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring on the basis of our legitimate interests in operating a safe and sustainable platform, provided those interests are not overridden by your privacy rights.
• Consent: Where processing is based on your consent — such as the receipt of marketing communications — you may withdraw that consent at any time by contacting [email protected] or using the opt-out mechanism in any marketing email you receive. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Payment Service Providers

To process deposits and withdrawals, ph111 shares necessary transaction data with payment service providers including bKash, Nagad, Rocket, Upay, and partner banks such as Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank. These providers receive only the data needed to authorise and complete the relevant transaction.

Game Studio Providers

Games on ph111 are delivered by third-party studios including Pragmatic Play, Evolution Gaming, PG Soft, JILI, Spribe, Microgaming, Ezugi, and Habanero. These providers may receive a player session token and anonymised session identifiers to deliver their games; they do not receive your full name, address, or payment details.

Identity Verification Partners

ph111 may use third-party identity verification services to assist with KYC processing. These partners act as data processors on ph111's behalf and are bound by contractual data protection obligations that prohibit any use of player data beyond the scope of the verification service.

Legal and Regulatory Authorities

ph111 will disclose personal data to law enforcement agencies, regulatory bodies, or courts in Bangladesh or other relevant jurisdictions where required to do so by law, court order, or regulatory directive. ph111 will notify affected players of such disclosures where permitted by law.

Fraud Prevention Networks

Where ph111 identifies activity consistent with fraud, money laundering, or collusion, it may share relevant account data with industry fraud-prevention networks or other gaming operators for the purpose of protecting the integrity of online gaming. Such sharing is conducted on a strictly need-to-know basis.

Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial part of ph111's business assets, player data may be transferred to the acquiring entity as part of that transaction. ph111 will notify affected players in advance of any such transfer and will ensure that the receiving entity is bound by data protection obligations at least equivalent to those in this Privacy Policy.

ph111 uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device by the ph111 website when you visit. The following categories of cookies are used on ph111.im:

You can manage or delete cookies at any time through your browser settings. Most modern browsers allow you to block third-party cookies, clear existing cookies, or receive a notification before a cookie is set. Please note that disabling strictly necessary cookies will prevent you from logging into your ph111 account and using core platform features.

ph111 does not use cookies to serve third-party advertising or to build advertising profiles based on your browsing behaviour across other websites.

ph111 retains personal data for as long as necessary to fulfil the purpose for which it was collected, and for as long as required by applicable law. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your account with ph111, plus a minimum post-closure retention period of five (5) years to satisfy financial record-keeping and anti-money laundering requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of account closure, in accordance with standard compliance practice for online gaming platforms.
• Transaction Records: All deposit and withdrawal records are retained for a minimum of five (5) years from the date of each transaction.
• Betting and Gaming History: Retained for a minimum of three (3) years from the date of each session, primarily for dispute resolution and responsible gaming monitoring purposes.
• Support Communications: Retained for two (2) years from the date of the last message in the relevant support thread.
• Marketing Opt-In Records: Retained for the duration of your marketing consent, plus one (1) year after you withdraw consent, to demonstrate compliance with consent obligations.
• Technical Logs (IP, Device): Retained for up to ninety (90) days for security monitoring purposes, after which they are aggregated and anonymised.

When retention periods expire, personal data is securely deleted using industry-standard data destruction methods, or anonymised such that it can no longer be linked to any individual player. Anonymised and aggregated data may be retained indefinitely for statistical and business analysis purposes.

ph111 takes the security of your personal data seriously. We implement a combination of technical, organisational, and procedural measures designed to protect player data against unauthorised access, accidental loss, alteration, or disclosure.

Technical Safeguards

• SSL/TLS Encryption: All data in transit between your browser and ph111's servers is encrypted using industry-standard SSL/TLS protocols. You can verify this by checking for the padlock icon in your browser's address bar when visiting ph111.im.
• Encryption at Rest: Sensitive data stored on ph111's servers — including identity documents, payment details, and account credentials — is encrypted at rest using AES-256 encryption or equivalent.
• Access Controls: Access to personal player data within ph111's internal systems is restricted on a strict need-to-know basis. Staff members can only access the data necessary for their specific job function.
• Intrusion Detection: ph111 operates continuous security monitoring systems designed to detect and respond to unauthorised access attempts, anomalous traffic patterns, and other indicators of compromise in real time.
• Two-Factor Authentication: ph111 offers and encourages the use of two-factor authentication (2FA) for player accounts to add an additional layer of protection beyond username and password.

Organisational Safeguards

• All ph111 staff with access to personal data are bound by confidentiality obligations and receive regular training on data handling best practices.
• Third-party vendors and data processors who handle ph111 player data are subject to data processing agreements that impose security and confidentiality standards equivalent to those applied internally.
• ph111 conducts periodic internal reviews of its data security practices to identify and remediate vulnerabilities.

Data Breach Response

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph111 will notify affected players without undue delay. Notifications will be sent to the email address registered on your account and will include a description of the nature of the breach, the categories and approximate number of individuals affected, the likely consequences, and the measures ph111 has taken or proposes to take to address the breach.

Despite the measures ph111 has in place, no internet-based platform can guarantee absolute security. You play an important role in protecting your own account by using a strong, unique password, not sharing your credentials, and notifying ph111 immediately if you suspect any unauthorised access to your account.

ph111 uses date of birth information collected at registration, combined with KYC identity verification, to enforce the 18+ age restriction. Any account found to belong to a person under the age of 18 will be immediately closed, all associated data will be securely deleted (subject to any legal retention obligations), and any wagers placed will be voided.

If you are a parent or guardian and believe that your child may have created a ph111 account, please contact us immediately at [email protected] with the subject line "Underage Account Report". ph111 will investigate the report promptly and take appropriate action.

ph111 does not direct any marketing communications, game content, or promotional materials at individuals under the age of 18. Our advertising and outreach efforts are targeted exclusively at adults in Bangladesh who have voluntarily expressed an interest in online gaming and sports betting.

ph111 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or platform features. When we make material changes to this Policy, we will provide notice through one or more of the following channels: a prominent notice on ph111.im at the time of your next login, an email notification to your registered email address, or an announcement on the ph111 homepage.

The "Last Updated" date displayed at the top of this document reflects the date on which the current version of this Privacy Policy entered into force. We encourage you to review this page periodically to stay informed about how ph111 handles your personal data.

Your continued use of the ph111 platform after any update to this Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any changes to this Policy, you should stop using ph111 and may request account closure in accordance with the process described in the ph111 Terms & Conditions.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the handling of your personal data by ph111, please contact our support team via live chat (available 24 hours a day, 7 days a week) or by email at [email protected]. Our team operates on Bangladesh Standard Time (BST, UTC+6) and aims to respond to all written privacy enquiries within 5 business days.