ax111 Privacy Policy — How We Collect, Use & Protect Your Data

1. Introduction

ax111 ("the Company", "we", "us", "our") is committed to protecting the privacy and security of personal information belonging to our members ("you", "your"). This Privacy Policy ("Policy") describes how ax111 collects, processes, stores, and shares personal data in connection with your use of the ax111 platform, including all services accessible via ax111.org — sports betting markets covering PSL, international cricket, and UFC, casino games such as slots, baccarat, and joker poker, the ax111 Login system, cashier services, and all customer support channels.

This Policy forms part of the contractual relationship between you and ax111, alongside our Terms & Conditions and Responsible Gaming Policy. By registering an ax111 account or continuing to use the platform, you acknowledge that you have read, understood, and agreed to the data practices described in this Policy.

ax111 operates as a data controller in respect of personal data collected directly from members. Where we engage third-party service providers to process data on our behalf — such as KYC verification partners or payment processors like JazzCash and EasyPaisa — those parties act as data processors under contractual obligations consistent with this Policy.

2. Personal Data We Collect

ax111 collects personal data through several channels: directly from you during registration and account management, automatically through your use of the platform, and from regulated third parties where permitted by applicable law. The categories of data we collect include:

2.1 Registration & Identity Data

When you create an ax111 account, we collect your full legal name as it appears on your Pakistani CNIC or passport, your date of birth, a valid Pakistani mobile number, and your email address. This data is essential to establish your identity, enforce our 21+ age policy, and satisfy Know Your Customer (KYC) requirements under applicable anti-money laundering regulations.

2.2 Financial & Payment Data

To process deposits and withdrawals in PKR, ax111 collects payment method identifiers associated with your JazzCash wallet, EasyPaisa account, HBL or UBL bank account, Meezan Bank details, Raast ID, or Visa/Mastercard credentials. Full card numbers are never stored on ax111 servers — payment data is tokenised and handled by PCI-DSS compliant payment processors. We retain transaction records including deposit amounts, withdrawal requests, and timestamps for regulatory and audit purposes.

2.3 Identity Verification Documents

As part of our KYC process, we may collect scanned copies or photographs of your CNIC (front and back), passport, or driving licence, along with a proof of address document such as a recent utility bill or bank statement. These documents are reviewed by our compliance team and stored securely for the period required by applicable data retention obligations.

2.4 Technical & Usage Data

ax111 automatically collects certain technical data when you access the platform, including your IP address, device type and operating system, browser type and version, session duration, pages visited, games played, betting history, and referral source. This data is used for platform security, fraud detection, product improvement, and responsible gaming monitoring purposes.

2.5 Communications Data

When you contact ax111 support via live chat or email at [email protected], we retain records of those communications including timestamps, agent responses, and any attachments or screenshots you share. These records help us resolve disputes, improve service quality, and comply with regulatory obligations.

3. How We Use Your Personal Data

ax111 processes your personal data on the following lawful bases and for the following specific purposes:

• Account Administration: Creating, maintaining, and securing your ax111 member account, processing your ax111 Login authentication, and managing your profile settings and preferences.
• Payment Processing: Facilitating PKR deposits and withdrawals through your chosen payment method, reconciling transactions, and processing refunds where applicable.
• Regulatory Compliance: Satisfying KYC, anti-money laundering (AML), and counter-terrorism financing (CTF) obligations as required by applicable financial regulations. This includes screening members against sanctions lists and politically exposed persons (PEP) databases.
• Fraud Prevention & Security: Monitoring account activity for signs of fraud, unauthorised access, bonus abuse, collusion, or match-fixing in connection with PSL cricket and other sports betting markets.
• Responsible Gaming: Analysing your gaming patterns to identify indicators of problem gambling behaviour, and providing proactive responsible gaming interventions where appropriate, including deposit limit reminders and cooling-off suggestions.
• Platform Improvement: Using aggregated, anonymised usage data to improve game performance, optimise the ax111 Casino interface, and develop new features that benefit the Pakistani gaming community.
• Customer Support: Responding to enquiries, resolving disputes, and processing complaints submitted through live chat or email.
• Marketing Communications: Sending promotional communications about ax111 bonuses, new game launches, and PSL-season betting offers — but only where you have provided explicit consent to receive such communications. You may withdraw consent at any time.

4. Sharing & Disclosure of Personal Data

ax111 treats member data with strict confidentiality. We do not sell your personal data. We share data only in the following limited circumstances:

4.1 Payment Processors

To execute PKR transactions, ax111 shares necessary payment identifiers with regulated payment service providers including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and international card networks (Visa, Mastercard). These providers are contractually obligated to process data only for the specific purpose of completing your transaction.

4.2 KYC & Identity Verification Partners

ax111 engages regulated third-party KYC providers to verify the identity documents submitted by members. These providers are bound by strict data processing agreements and may not use your identity data for any purpose beyond the specific verification service they perform for ax111.

4.3 Legal & Regulatory Authorities

ax111 may disclose personal data to law enforcement agencies, financial intelligence units, or other competent regulatory authorities where required by applicable law, court order, or regulatory directive. In such cases, ax111 will share the minimum data necessary to comply with the legal obligation.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial portion of ax111's assets, member personal data may be transferred to the acquiring entity as part of that transaction. ax111 will notify affected members in advance where permitted by applicable confidentiality obligations and will ensure the receiving entity adopts data protection standards consistent with this Policy.

5. Cookies & Tracking Technologies

ax111 uses cookies and similar technologies — including local storage and session storage — to operate the platform effectively. The categories of cookies deployed on ax111.org are as follows:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies used by the ax111 Login system, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without disrupting platform functionality.
• Performance & Analytics Cookies: Used to understand how members interact with ax111 — for example, which game pages receive the most visits, average session duration, and page load performance. All data collected by analytics cookies is aggregated and anonymised.
• Fraud Prevention Cookies: Help ax111 identify and block suspicious activity, including multi-accounting, bonus abuse, and automated bot traffic. These cookies analyse device fingerprints and behavioural patterns in a privacy-preserving manner.
• Preference Cookies: Remember your platform settings such as language preference, display theme, and responsible gaming notification settings, so you do not need to re-configure these on each visit.

ax111 does not deploy third-party advertising cookies, social media trackers, or any cross-site behavioural profiling technology. You may manage or disable non-essential cookies through your browser settings. Note that disabling strictly necessary cookies will affect platform functionality, including your ability to log in.

6. Data Security

ax111 implements a layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit TLS encryption for all data in transit between your device and ax111 servers.
• AES-256 encryption for sensitive data at rest, including identity documents and payment records.
• Bcrypt hashing with individually generated salts for all member passwords — plaintext passwords are never stored.
• Role-based access controls (RBAC) ensuring that ax111 staff can access only the specific member data necessary for their job function.
• Multi-factor authentication (MFA) enforced for all internal ax111 staff systems handling member data.
• Regular third-party penetration testing and security audits of the ax111 platform infrastructure.
• Automated anomaly detection systems that flag unusual access patterns for immediate security review.

Despite these measures, no digital platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, ax111 will notify affected members and relevant regulatory authorities without undue delay in accordance with applicable data breach notification requirements.

7. Data Retention

ax111 retains your personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal and regulatory obligations. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active ax111 membership plus a minimum of five years following account closure, to comply with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five years from the date of each transaction in accordance with financial record-keeping obligations.
• KYC Documents: Retained for the period required by applicable anti-money laundering regulations in the relevant jurisdiction, typically five to seven years.
• Support Communications: Retained for three years from the date of last contact, after which they are securely deleted unless a dispute or legal proceeding requires longer retention.
• Marketing Consent Records: Retained for the duration of your active consent plus two years, to provide evidence of consent in case of dispute.

When data is no longer required, it is securely deleted or irreversibly anonymised using industry-standard data sanitisation techniques.

8. Your Data Rights

As an ax111 member, you have the following rights in respect of the personal data we hold about you. To exercise any of these rights, contact our support team via live chat or at [email protected] and we will respond within 30 calendar days:

• Right of Access: You may request a copy of the personal data ax111 holds about you, together with information about how it is processed.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you may request that we correct it. For account-level corrections, you can also update most details directly through your profile settings.
• Right to Erasure: You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose it was collected, or where you withdraw consent. Note that we may be required to retain certain data for regulatory compliance reasons even following an erasure request.
• Right to Restrict Processing: You may request that ax111 restricts the processing of your data in certain circumstances, such as while the accuracy of data is being contested.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing of your personal data for direct marketing purposes at any time. You may also opt out of marketing emails directly using the unsubscribe link included in every promotional communication from ax111.

9. Protection of Minors

ax111 operates a strict 21+ age policy. The ax111 platform is not directed at, and must not be used by, any individual under the age of 21 years. We do not knowingly collect personal data from individuals under this age threshold. Our registration process includes age verification steps, and we reserve the right to request CNIC or passport documentation at any stage to confirm age compliance.

If ax111 becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, we will immediately suspend the associated account, delete the data collected, and return any deposited funds to the source payment method following a verification process. Parents and guardians who have reason to believe a minor has registered with ax111 are strongly encouraged to contact us immediately at [email protected].

10. Third-Party Services & Links

The ax111 platform integrates with third-party services including payment processors, game content providers, and identity verification services. While ax111 selects partners who demonstrate high standards of data protection, once you leave the ax111 platform and interact directly with a third-party service, that party's own privacy policy governs the use of your data and ax111 accepts no responsibility for their data practices.

Game content on ax111 is supplied by licensed third-party game providers. These providers may collect aggregated, anonymised game interaction data for their own game performance analytics. They do not receive your ax111 account identity data, payment information, or contact details unless you explicitly interact with their support services independently of ax111.

11. Changes to This Privacy Policy

ax111 may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable legal requirements. Where updates are material — for example, changes to the categories of data we collect, new third-party sharing arrangements, or changes to your data rights — ax111 will provide advance notice via a prominent on-site banner or direct email notification to your registered address at least 14 days before the changes take effect.

Minor or clarificatory updates may be made without advance notice. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. The current version of this Policy is always available at ax111.org/privacy-policy. Your continued use of the ax111 platform after any update constitutes acceptance of the revised Policy.

12. Contact & Data Enquiries

If you have any questions about this Privacy Policy, wish to exercise a data right, or wish to raise a concern about how ax111 handles your personal data, please reach out through any of the following channels:

• Live Chat: Available 24/7 directly on the ax111 platform. Average response time is 3–5 minutes. Support is available in both English and Urdu.
• Email: [email protected] — responses within 24 hours on business days.