Privacy Policy —
How dk111 Protects Your Data

1.1 This Privacy Policy ("Policy") describes the data practices of dk111 ("we," "us," "our," "dk111") as they apply to all individuals ("you," "Member," "User") who interact with the dk111 online gaming and sports betting platform, including through the website dk111.bio, any related mobile-optimised interfaces, customer support channels, and marketing communications.

1.2 dk111 serves players across Pakistan, including in Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and all other cities and regions. This Policy has been written to be clear and accessible to Pakistani users while also meeting the requirements of applicable international data protection standards under which dk111 operates.

1.3 This Policy applies to personal data collected directly from Members as well as data that may be derived from your interactions with the Platform, your gaming and betting behaviour, and technical data generated by your devices and browsers when accessing dk111.

1.4 This Policy should be read in conjunction with the dk111 Terms & Conditions and the Responsible Gaming Policy, all of which are incorporated by reference and form part of the overall agreement between you and dk111.

1.5 This Policy applies to all individuals aged 21 and above who are eligible to use the dk111 Platform. Persons under the age of 21 are prohibited from using dk111 services and, consequently, from providing personal data to dk111. Any personal data inadvertently collected from a person under 21 will be deleted upon identification.

2.1 For the purposes of applicable data protection law, dk111 is the data controller in respect of all personal data processed under this Policy. As data controller, dk111 determines the purposes and means of processing your personal information.

2.2 dk111 operates under an international gaming licence that includes data protection compliance obligations. Our data processing activities are conducted in accordance with both our licensing requirements and recognised international data protection principles.

2.3 Where dk111 engages third-party service providers (such as payment processors, identity verification agencies, game content providers, and cloud infrastructure providers) to process personal data on our behalf, these parties act as data processors under binding data processing agreements that prohibit them from using your data for their own purposes.

2.4 For all privacy-related queries, data access requests, or complaints, please contact dk111 via email at [email protected]. Communications should be marked "Privacy — Data Enquiry" to ensure prompt routing to the responsible team.

3.1 dk111 collects personal data through several channels: directly from you during registration and account operation, automatically through your use of the Platform, and in certain circumstances from third-party sources such as identity verification agencies and payment processors.

3.2 Registration Data. When you create a dk111 account, we collect: your full legal name, date of birth, Pakistani mobile number, email address, and CNIC (Computerised National Identity Card) number. This information is mandatory for account creation and KYC compliance.

3.3 Identity Verification Data. To comply with our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, dk111 may collect copies of your CNIC, proof of address documentation, and source of funds evidence. This data is processed by our identity verification partner under strict contractual data protection obligations.

3.4 Financial Data. dk111 collects transaction records including deposit amounts, withdrawal requests, payment method identifiers (e.g., JazzCash account reference, EasyPaisa wallet reference, bank account numbers), and transaction timestamps. Full payment card or bank account numbers are not stored by dk111 — these are handled directly by our licensed payment processors.

3.5 Gaming & Betting Activity Data. We record your betting and gaming activity including game history, bet amounts, results, session durations, and in-play decision patterns. This data is used for account administration, responsible gaming monitoring, and dispute resolution.

3.6 Technical & Device Data. When you access dk111, we automatically collect technical data including your IP address, device type, operating system version, browser type, screen resolution, and connection type. This data is used for platform optimisation, fraud detection, and security monitoring.

3.7 Communications Data. If you contact dk111 customer support via live chat, email, or any other channel, we retain records of those communications including the content, timestamps, and outcomes. This data is used for quality assurance, training, and dispute resolution.

3.8 The categories of personal data collected from dk111 members are summarised in the table below:

4.1 dk111 uses your personal data exclusively for legitimate purposes that are necessary to operate our platform, comply with our legal obligations, and deliver a high-quality gaming experience to members across Pakistan. We do not use your data for purposes incompatible with those stated below.

4.2 The primary purposes for which dk111 processes your personal data include:

• Account Registration & Management: Creating and maintaining your dk111 Member Account, verifying your identity and age (21+), managing your login credentials, and administering account settings.
• Service Delivery: Processing your bets, settling gaming results, crediting winnings, managing bonus offers, and providing access to all dk111 Platform features including cricket betting, live casino, slots, poker, and circle games.
• Payment Processing: Processing deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other approved payment channels; executing withdrawal requests to your registered payment method; maintaining transaction records.
• Legal & Regulatory Compliance: Fulfilling AML, KYC, counter-terrorism financing, and responsible gaming legal obligations; responding to regulatory enquiries; maintaining records required by our gaming licence conditions.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, money laundering, and any conduct that threatens the integrity of the dk111 Platform or its members.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviour; implementing deposit limits, self-exclusion, and cooling-off restrictions where appropriate; maintaining self-exclusion registers.
• Customer Support: Responding to queries, resolving disputes, investigating complaints, and improving our support processes based on communication records.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the dk111 user experience, identify technical issues, and develop new features that better serve Pakistani players.
• Marketing Communications (with consent): Sending promotional communications about dk111 offers, new games, and Platform updates where you have consented to receive such communications and have not subsequently withdrawn that consent.

5.1 dk111 processes your personal data only where there is a valid lawful basis for doing so. The specific legal basis applicable to each processing activity is identified below:

• Contractual Necessity: Processing required to perform our obligations under the dk111 Terms & Conditions, including account creation, service delivery, and payment processing.
• Legal Obligation: Processing required by applicable law, including AML regulations, KYC obligations, regulatory reporting requirements, and self-exclusion compliance under our gaming licence.
• Legitimate Interests: Processing conducted for the purposes of fraud prevention, security monitoring, responsible gaming oversight, dispute resolution, and Platform improvement — where these interests do not override your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6.1 dk111 uses cookies and similar tracking technologies on the Platform to provide core functionality, maintain your login session, protect your account security, and understand how you interact with the Platform in order to improve it.

6.2 The types of cookies used by dk111 are:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged into your dk111 account and security cookies that protect against cross-site request forgery. Essential cookies cannot be disabled without rendering the Platform non-functional.
• Functional Cookies: Store your Platform preferences such as language selection, display settings, and notification configurations. These cookies improve your experience but are not essential to Platform operation.
• Analytics Cookies: Used to understand how Members interact with the Platform, which features are most used, and where technical problems are encountered. Data collected by analytics cookies is aggregated and anonymised. dk111 uses analytics data solely for Platform improvement.
• Security Cookies: Used for fraud detection and account protection, including device fingerprinting to identify suspicious login attempts from unrecognised devices.

6.3 dk111 does not use third-party advertising cookies or allow external advertising networks to place tracking cookies on the Platform. Your gaming behaviour on dk111 is not shared with advertising platforms.

6.4 You may manage cookie preferences through your browser settings. Note that disabling certain cookies may impair Platform functionality. Specific cookie consent preferences can also be managed through the cookie preference centre accessible from the dk111 website footer.

7.1 dk111 does not sell, rent, lease, or otherwise commercially transfer your personal data to any third party. Data sharing is conducted only where necessary and only with the categories of recipient described in this section.

7.2 Payment Processors. Transaction data is shared with licensed payment processors (including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast/1LINK) to the extent necessary to process your deposits and withdrawal requests. These parties are independent data controllers in respect of the transaction data they receive and are governed by their own privacy policies and regulatory obligations.

7.3 Identity Verification Providers. KYC documentation including CNIC copies and proof of address is processed by dk111's appointed identity verification partner. This partner acts as a data processor under a binding agreement that prohibits use of the data beyond identity verification services for dk111.

7.4 Regulatory Authorities. dk111 is required by law and by the conditions of our gaming licence to share certain information with regulatory authorities, including anti-money-laundering reporting bodies, gaming regulators, and law enforcement agencies where legally compelled. Such disclosures are made only to the extent required by law and on a case-by-case basis.

7.5 Technology Service Providers. dk111 uses cloud infrastructure, cybersecurity, analytics, and customer support software providers who may process personal data on our behalf as data processors. All such providers are bound by data processing agreements that restrict their use of your data to the specific services they provide to dk111.

7.6 Game Content Providers. Where you play games from third-party studios available on the dk111 platform, limited technical and gameplay data may be transmitted to the relevant game provider to operate the game. This is contractually governed and does not include financial or identity data.

7.7 Self-Exclusion Registers. If you activate a self-exclusion through dk111, your name and relevant identification details may be shared with multi-operator self-exclusion schemes where dk111 participates, for the purpose of enforcing your exclusion across participating platforms. This sharing is conducted for your protection and in compliance with responsible gaming regulations.

8.1 dk111 operates under an international gaming licence and uses cloud infrastructure and service providers located in multiple jurisdictions. As a result, your personal data may be transferred to and processed in countries outside Pakistan.

8.2 Where personal data is transferred to countries that do not provide a level of data protection equivalent to international standards, dk111 ensures that appropriate safeguards are in place. These safeguards may include standard contractual clauses, binding corporate rules, or reliance on the recipient country's adequacy determination.

8.3 By using the dk111 Platform and providing your personal data, you acknowledge that your data may be transferred, stored, and processed in countries outside Pakistan as described in this section. Such transfers are conducted in compliance with applicable data protection obligations and solely for the purposes described in this Policy.

9.1 dk111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce our Terms & Conditions.

9.2 The general retention periods applied by dk111 are as follows:

• Account & Identity Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, in accordance with AML and gaming licence record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable financial regulations.
• Gaming & Betting Activity Data: Retained for a minimum of three (3) years from the date of each gaming session, for dispute resolution and responsible gaming monitoring purposes.
• Customer Support Communications: Retained for up to two (2) years from the date of the interaction, unless a longer period is required for an ongoing dispute or legal matter.
• Technical & Device Data (Logs): Retained for up to twelve (12) months from the date of collection, unless specific logs are required for security investigations.
• Self-Exclusion Data: Retained for the duration of the self-exclusion period plus five (5) years after expiry, to support enforcement and reapplication decisions.
• Marketing Consent Records: Retained for the duration of the consent plus three (3) years after its withdrawal, to demonstrate compliance with consent obligations.

9.3 When retention periods expire, personal data is securely deleted or anonymised in accordance with dk111's data destruction procedures. Anonymised data (which cannot be re-linked to any individual) may be retained indefinitely for statistical and analytical purposes.

10.1 dk111 implements comprehensive technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction.

10.2 Our key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and dk111 servers.
• AES-256 encryption for sensitive data stored at rest, including passwords, KYC documents, and payment references.
• Password hashing using industry-standard algorithms — no plaintext passwords are ever stored.
• Two-factor authentication (2FA) available for all Member Accounts.
• Real-time fraud monitoring and anomaly detection systems that flag unusual account activity.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular independent security audits and penetration testing of dk111 systems.
• Incident response procedures including Member notification protocols in the event of a confirmed data breach.

10.3 Notwithstanding these measures, no electronic system is completely immune to security risks. dk111 encourages Members to use strong unique passwords for their dk111 Account, enable two-factor authentication, and promptly notify dk111 of any suspected unauthorised activity.

10.4 In the event that dk111 becomes aware of a data breach that is likely to result in a risk to the rights and freedoms of affected Members, we will notify affected individuals without undue delay and, where required by law, report the breach to the relevant regulatory authority.

11.1 dk111 is strictly an adults-only platform. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Age verification is a mandatory step in the dk111 registration process, and all accounts are subject to CNIC-based age confirmation.

11.2 If dk111 becomes aware that personal data has been inadvertently collected from a person under the age of 21, we will promptly delete that data and permanently close the relevant account.

11.3 If you are a parent or guardian and believe that a minor in your care has registered an account or provided personal data to dk111, please contact us immediately at [email protected] with the subject line "Minor Account Report" so that we can investigate and take appropriate action.

12.1 As a dk111 Member, you have the following rights in relation to your personal data processed by dk111. These rights may be exercised by contacting us at [email protected]:

• Right of Access: You may request a copy of all personal data dk111 holds about you, along with information about how it is used, where it came from, and with whom it has been shared.
• Right to Rectification: If any personal data dk111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Some corrections (e.g., name or CNIC updates) require additional identity verification.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. This right is subject to exceptions where dk111 is required by law or gaming regulation to retain your data.
• Right to Restriction: You may request that dk111 restrict the processing of your personal data while a dispute about its accuracy is resolved, or while you exercise other rights.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider, where processing is based on consent or contract.
• Right to Object: You may object to processing of your personal data carried out on the basis of legitimate interests, including profiling for marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

12.2 dk111 will respond to data rights requests within 30 calendar days of receipt. Requests may be extended by a further 60 days in complex cases, with notification provided to you explaining the reason for extension.

12.3 Exercising your data rights is free of charge. However, dk111 reserves the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests, particularly where they are repetitive in nature.

13.1 dk111 may send promotional communications about Platform offers, new games, bonuses, and related services to Members who have consented to receive such communications. Consent is requested during the registration process and may be managed at any time from within your Account settings.

13.2 Marketing communications may be delivered via SMS to your registered Pakistani mobile number, email to your registered address, or in-Platform notifications. Each type of marketing communication can be opted into or out of independently.

13.3 To opt out of all marketing communications from dk111, you may: update your communication preferences in Account Settings; click the unsubscribe link in any dk111 marketing email; or contact customer support via live chat or at [email protected].

13.4 Opting out of marketing communications does not affect service communications (such as deposit confirmations, withdrawal notifications, account security alerts, and responsible gaming notices), which are sent as necessary for account administration regardless of marketing preferences.

13.5 dk111 does not engage in automated decision-making or profiling for marketing purposes that produces legal effects on you or similarly significantly affects you without human review.

14.1 The dk111 Platform may contain references to third-party content providers and game studios. Where you interact with third-party game content on the dk111 Platform, that interaction may be subject to the third party's own privacy terms in addition to this Policy.

14.2 dk111 is not responsible for the privacy practices of any third-party game studios, payment processors as independent controllers, or any other third parties. We encourage you to review the privacy notices of any third-party services with which you interact.

14.3 dk111 does not control the data practices of third-party payment processors in their capacity as independent data controllers for payment transaction data. Their handling of your financial information is governed by their own regulatory obligations and privacy notices.

15.1 dk111 reserves the right to update this Privacy Policy at any time. Material changes — those that significantly affect how your personal data is used — will be communicated to you via email to your registered address or SMS to your registered Pakistani mobile number at least 14 days before the changes take effect.

15.2 Non-material changes such as typographical corrections, clarifications, and formatting improvements may be implemented without prior notice. The date of the most recent update is displayed at the top of this Policy and in the Table of Contents.

15.3 Continued use of the dk111 Platform following the effective date of any Policy amendment constitutes your acknowledgement of the updated Privacy Policy. If you do not agree with any material amendment, you should close your Account before the amendment takes effect and contact us to exercise any applicable data rights.

15.4 Historical versions of this Privacy Policy are available on request from dk111 customer support. Please reference the version date when making such a request.

16.1 For any questions, concerns, or requests relating to this Privacy Policy or dk111's data practices, please contact us through the following channels:

• Email: [email protected] — please mark privacy enquiries "Privacy — Data Enquiry" for prompt routing
• Live Chat: Available 24/7 via dk111.bio — English and Urdu support available
• Written Requests: Formal data rights requests should be submitted through your Account's support portal and marked "Data Rights Request"

16.2 dk111 is committed to resolving privacy concerns promptly and fairly. We will acknowledge all privacy communications within 48 hours and aim to resolve substantive matters within 30 days.

16.3 If you are not satisfied with dk111's response to a privacy complaint, you have the right to escalate the matter to the data protection authority or gaming regulator under whose jurisdiction dk111 operates. Details of the relevant regulatory body are available on request from dk111 support.