a111 Privacy Policy – How We Protect Your Personal Data

a111 operates the online betting and gaming platform available at a111.wine. For the purposes of this Privacy Policy, "a111", "we", "us" and "our" refer to the operator of a111.wine and all associated services offered through that domain.

a111 is the data controller for all personal information collected through the platform. This means we are responsible for determining how your personal data is used and for ensuring it is handled in accordance with this Privacy Policy. If you have any questions about our data practices, you can reach us at support@a111.wine at any time.

This Privacy Policy applies to all registered and unregistered users who visit or interact with a111.wine, including players who register accounts, make deposits, place bets, or simply browse the platform without registering. By using a111 in any way, you acknowledge that you have read this Privacy Policy.

a111 collects different categories of personal data depending on how you use the platform. Below is a breakdown of the types of information we may hold about you.

a111 collects personal data through several channels, all of which are directly related to your use of the platform:

• Registration: When you create your a111 account, you provide your name, mobile number and date of birth directly. This is the core information needed to open and maintain your account.
• Deposits and withdrawals: When you deposit or withdraw funds via Easypaisa, JazzCash, bank IBFT or card, transactional information is captured to process your request and maintain account records.
• Identity verification: Where a111 requests verification documents (CNIC, selfie), you upload these directly through the platform's secure verification interface.
• Platform activity: Your betting and gaming activity on a111 is recorded automatically as part of the platform's normal operation — this is necessary to settle bets, credit winnings, and maintain a complete transaction history.
• Cookies and tracking technologies: Automatically when you visit a111.wine — see Section 8 for full details on what we collect this way.
• Support interactions: When you contact a111 via live chat or email, the content of those communications is captured and stored.
• Referrals: If you join a111 through the Refer a Friend programme, the referring player's account is noted for the purpose of crediting the referral reward. Only the referring player's a111 account ID is associated with your registration — no additional data from the referrer is shared with you or vice versa.

a111 uses your personal data only for specific, legitimate purposes. We do not process your data for any purpose that is not described here without first obtaining your explicit consent.

a111 processes your personal data under the following legal grounds, depending on the specific processing activity:

• Contractual necessity: Processing your identity, financial and gaming data is necessary to fulfil the contract between you and a111 — without it, we cannot operate your account, process payments or settle your bets.
• Legal obligation: a111 is required by applicable law and platform regulations to verify user identities, maintain transaction records, and cooperate with regulatory investigations. Processing for these purposes is mandatory.
• Legitimate interests: a111 has a legitimate interest in preventing fraud, protecting the platform from abuse, improving its services, and operating a responsible gaming environment. These interests are balanced against your rights and privacy interests.
• Consent: For optional processing activities — such as sending you marketing communications — a111 will ask for your explicit consent first. You can withdraw consent for these activities at any time without affecting any other aspect of your account.

a111 retains personal data for as long as it is necessary for the purposes described in this Privacy Policy, or as required by applicable law and regulatory obligations. Specific retention periods are as follows:

• Account data: Retained for the lifetime of your a111 account plus a minimum of five years after account closure, to meet regulatory and anti-money laundering obligations.
• Financial transaction records: Retained for at least five years from the date of each transaction, as required by financial recordkeeping standards.
• Identity verification documents: Retained for the period required by applicable regulations, typically five years after the closure of your account.
• Gaming and betting history: Retained for the lifetime of your account and for a minimum of two years after closure for responsible gaming monitoring purposes.
• Support communications: Retained for a period of three years from the date of the interaction.
• Technical and device data: Retained for up to 13 months for analytics and fraud detection purposes, after which it is anonymised or deleted.

When data is no longer needed for any purpose and its retention period has passed, a111 deletes or anonymises it securely.

a111 does not sell your personal data to any third party, full stop. However, we do share data with certain trusted parties where it is strictly necessary to operate the platform or comply with legal requirements:

• Payment processors: When you make a deposit or withdrawal, your transaction details are shared with Easypaisa, JazzCash, NayaPay, SadaPay, or your bank or card provider as necessary to process the payment. These providers have their own privacy policies and are independent data controllers for the payment processing step.
• Identity verification services: Where a111 uses a third-party identity verification provider to assist with age and identity checks, your verification documents may be processed by that provider. All such providers are contractually bound to handle your data only for verification purposes and to delete it once the process is complete.
• Game and platform technology providers: Certain games on a111 are provided by licensed third-party game studios. Aggregated, non-identifiable game session data may be shared with these providers for technical performance purposes. No personally identifiable information is shared with game studios without your knowledge.
• Law enforcement and regulators: a111 will disclose your data to relevant authorities where legally compelled to do so — for example, in response to a valid court order, regulatory investigation, or anti-money laundering inquiry. a111 will not voluntarily disclose your data to law enforcement beyond what is legally required.
• Professional advisers: In certain circumstances, a111 may share data with legal advisers, auditors or other professional consultants who are subject to confidentiality obligations.

a111.wine uses cookies and similar technologies to make the platform work, improve your experience, and keep your account secure. Here is an overview of what we use and why:

• Essential cookies: These are required for the platform to function. They maintain your login session, remember your language preferences, and enable secure connections. You cannot opt out of these without preventing a111 from working.
• Performance cookies: These cookies collect anonymous data about how pages are used — which features are most popular, how long sessions last, and where errors occur. This data helps a111 identify improvements. No personally identifiable data is included.
• Fraud detection cookies: a111 uses certain technical identifiers to detect suspicious patterns — such as multiple account registration attempts from the same device. These identifiers are stored securely and are only used for security purposes.
• Preference cookies: These remember your settings on a111, such as table preferences in poker or your default deposit method.

When you first visit a111.wine, you will be presented with a cookie consent notice. You can accept all cookies or manage your preferences. Withdrawing consent for non-essential cookies will not affect your ability to use the core betting and gaming features of a111.

a111 takes data security seriously and has implemented a range of technical and organisational measures to protect your personal information against unauthorised access, loss, alteration, or disclosure:

• SSL/TLS encryption: All data transmitted between your device and a111.wine is encrypted using industry-standard SSL/TLS protocols. The padlock icon in your browser confirms this is active.
• Password hashing: Your account password is never stored in plain text. a111 uses one-way cryptographic hashing so that even a111's own staff cannot see your password.
• Access controls: Access to personal data within a111's systems is restricted to staff who need it to perform their specific job functions. All access is logged and reviewed regularly.
• Database encryption: Sensitive personal data fields — including identity documents and financial account identifiers — are stored in encrypted form within a111's databases.
• Regular security audits: a111's platform infrastructure is subject to regular security reviews and vulnerability assessments by qualified professionals.
• Incident response: In the unlikely event of a data breach that affects your personal information, a111 has procedures in place to identify, contain and respond to the incident. Affected users will be notified promptly where legally required to do so.

As an a111 user, you have the following rights regarding your personal data. To exercise any of these rights, contact us at support@a111.wine. We will respond to all valid requests within 30 days.

• Right of Access — You can request a copy of all personal data that a111 holds about you. This is provided free of charge for the first request.
• Right to Rectification — If any data a111 holds about you is inaccurate or incomplete, you can ask us to correct it. You can also update basic account information directly through your a111 account settings.
• Right to Erasure — You can request that a111 delete your personal data. We will honour this request where there is no legal or regulatory obligation requiring us to retain it. Certain transaction records must be kept for legal compliance reasons even after an account is closed.
• Right to Restrict Processing — You can ask a111 to pause its use of your data — for example, while you dispute its accuracy — without requesting full deletion.
• Right to Data Portability — You can request that a111 provides your data in a structured, machine-readable format so that you can transfer it to another service.
• Right to Object — You can object to a111 processing your data based on legitimate interests. Where your objection is valid, a111 will stop the relevant processing unless there are compelling grounds to continue.
• Right to Withdraw Consent — Where processing is based on your consent (e.g. marketing communications), you can withdraw that consent at any time through your account settings or by contacting us. Withdrawal does not affect processing that took place before you withdrew consent.

a111 is strictly an adult platform — no person under the age of 18 is permitted to register or use the service. a111 does not knowingly collect or retain personal data from anyone under 18 years of age.

If a111 discovers that a user is under 18, or if a parent or guardian notifies us that a minor has registered with a111, we will immediately close the account, delete the personal data associated with it, and take any steps required to prevent future access from that individual.

a111 uses age verification checks during registration and may request identity documentation at any time to confirm a user's age. We encourage parents and guardians to make use of device-level parental controls to prevent underage access to online betting and gaming platforms.

a111 may send you promotional messages — such as bonus offers, tournament announcements, and new game notifications — via SMS to your registered mobile number or via platform notifications. We will only do this where you have opted in to marketing communications during registration or in your account settings.

• You can opt out of marketing messages at any time through the notification settings in your a111 account.
• Opting out of marketing does not affect transactional communications — a111 will still send you messages required for your account operation, such as deposit confirmations, withdrawal notifications, and security alerts.
• a111 does not send marketing communications via third-party messaging apps or social media platforms without your explicit consent to those specific channels.
• We do not share your contact details with third-party marketers under any circumstances.

a111 may update this Privacy Policy from time to time as the platform evolves or as legal requirements change. When we make changes, we will update the "Last Updated" date at the top of this page and notify registered users through the platform's notification system for any material changes.

Material changes — those that significantly affect how we process your data or your rights — will be communicated at least 14 days before taking effect, giving you time to review and, if you disagree, to close your account before the changes apply to you.

Your continued use of a111 after a revised Privacy Policy has been published and any notice period has elapsed constitutes your acceptance of the revised policy.

If you have any questions about this Privacy Policy, want to exercise any of your data rights, or wish to raise a concern about how a111 handles your personal information, please get in touch through any of the following channels:

• Email: support@a111.wine — Privacy enquiries are handled by a dedicated team member and will receive a response within 72 hours.
• Live Chat: Available 24/7 through a111.wine in Urdu and English.
• FAQ: Common privacy questions are answered at /faq.