ka111 Privacy Policy — Your Data, Your Rights

ka111 (referred to in this policy as "we", "us", or "the Platform") is committed to protecting the privacy and personal data of all users. This Privacy Policy applies to all personal data collected through the ka111 website, its associated services, and any communications between ka111 and its users, including via email or live chat support.

This policy is intended to meet the standards of applicable data protection law and to be read in conjunction with the ka111 Terms and Conditions. In the event of any conflict between this Privacy Policy and the Terms and Conditions on the topic of data, this Privacy Policy shall take precedence with respect to data protection matters.

When you register, use, or interact with the ka111 Platform, we may collect the following categories of personal information:

• Identity and contact information: full legal name, date of birth, mobile number, email address, and residential address.
• Identity verification documents: copies of government-issued photo ID (e.g., National ID card, passport) and proof of address submitted during KYC verification.
• Financial information: transaction history, deposit and withdrawal records, payment method details (e.g., bKash account number, last four digits of card). We do not store full card numbers on our servers.
• Usage and behavioural data: pages visited, games played, session duration, click patterns, device type, operating system, browser type, and IP address.
• Communications data: records of correspondence with our support team via email or chat, including timestamps and content of messages.
• Geolocation data: approximate geographic location derived from your IP address, used to confirm eligibility and comply with regional restrictions.

We collect only the information that is necessary for providing our services, meeting legal obligations, and maintaining the security and integrity of the Platform. We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, unless explicitly required by applicable law.

The personal data we collect is used for the following purposes:

• Account creation and management: to register your account, verify your identity, and maintain your account in good standing throughout your use of the Platform.
• Transaction processing: to process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and other supported payment channels, and to maintain records of all financial activity on your account.
• Legal compliance: to fulfil our obligations under anti-money laundering (AML) regulations, age verification requirements, and any other applicable legal or regulatory obligations.
• Platform improvement and personalisation: to analyse how users interact with the Platform, improve our services, resolve technical issues, and where you have consented, to personalise your experience with relevant game recommendations and promotional offers.
• Security and fraud prevention: to monitor account activity for signs of fraud, collusion, money laundering, and other prohibited conduct as defined in our Terms and Conditions, and to take appropriate action where such activity is detected.

ka111 processes your personal data on the following legal bases:

• Contractual necessity: processing required to enter into or perform the contract between you and ka111 (i.e., providing you with the services you have requested).
• Legal obligation: processing necessary to comply with applicable laws and regulations, including AML, KYC, age verification, and data retention requirements.
• Legitimate interests: processing carried out for fraud detection, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: processing for marketing communications and personalisation, where you have explicitly opted in. You may withdraw consent at any time by contacting [email protected].

Where we rely on your consent as the legal basis for any processing activity, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to its withdrawal.

ka111 does not sell, rent, or trade your personal data. We may share your personal data with third parties only in the following limited circumstances:

• Payment processors: we share transactional data with payment service providers (such as bKash, Nagad) to facilitate deposits and withdrawals. These providers are bound by their own data protection obligations.
• Identity verification services: we may share identity documents with third-party KYC verification providers to fulfil our age verification and anti-money laundering obligations.
• Regulatory and law enforcement authorities: we may disclose your data to relevant government bodies, regulators, or law enforcement agencies where required to do so by applicable law or court order.
• Service providers: we may engage third-party vendors to support platform operations (e.g., hosting, analytics, fraud detection). These vendors are contractually prohibited from using your data for any purpose other than the specific service they provide to ka111.

All third parties with whom we share personal data are required to implement appropriate technical and organisational measures to protect that data. ka111 remains responsible for ensuring that any data sharing arrangement meets the standards set out in this Privacy Policy.

Subject to applicable law, you have the following rights with respect to your personal data held by ka111:

• Right of access: you may request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to rectification: if any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected or updated.
• Right to erasure: in certain circumstances, you may request that we delete your personal data. Note that we may be required to retain certain data for legal or regulatory reasons even after account closure.
• Right to restrict processing: you may request that we limit the way we use your personal data in certain circumstances, for example while a dispute is being resolved.
• Right to object: you may object to certain types of processing, including direct marketing. Where you object to direct marketing, we will cease that activity immediately upon receipt of your request.

ka111 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or regulatory reporting requirements. The specific retention period applicable to each category of data is determined by the nature of the data and the legal basis on which it was collected.

As a general guideline, the following retention periods apply:

• Account and identity data: retained for the duration of the account relationship and for a minimum of five years following account closure, in accordance with AML and KYC regulatory requirements.
• Transaction records: retained for a minimum of five years from the date of the transaction, or longer where required by applicable law.
• Support communications: retained for up to two years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution or legal proceedings.

ka111 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files placed on your device when you visit a website; they allow the Platform to recognise your device on subsequent visits. We use the following types of cookies:

• Essential cookies: required for the Platform to function correctly. These include session authentication cookies and security tokens. Disabling these cookies may prevent you from using core Platform features.
• Analytical cookies: used to collect aggregated, anonymised data about how users interact with the Platform. This data helps us understand which features are most popular and where improvements can be made.
• Preference cookies: used to remember your settings and preferences (such as language selection) to provide a more personalised experience on return visits.
• Marketing cookies: used, where you have consented, to track your activity across sessions and deliver relevant promotional content. You may withdraw consent to marketing cookies at any time via your browser settings.
• You can control and manage cookies through your browser settings. Please note that removing or blocking essential cookies may impact the functionality of the Platform and prevent you from accessing certain features.

We do not use cookies to collect sensitive personal data such as passwords, payment credentials, or government-issued ID numbers. All session and authentication data is transmitted over SSL-encrypted connections.

ka111 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include SSL encryption for all data in transit, access controls limiting data access to authorised personnel only, regular security audits and penetration testing of Platform infrastructure, and secure data storage practices with encrypted backups.

While we take all reasonable precautions to protect your data, no method of transmission over the internet or method of electronic storage is completely secure. If you have reason to believe that your account has been compromised, please contact [email protected] immediately so that we can take appropriate protective action.

The ka111 Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from any person under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. The following measures are in place to prevent underage access:

• Mandatory date-of-birth collection at registration, with all users required to confirm they are 21 or older before account creation is completed.
• Age verification checks carried out as part of the KYC process, requiring submission of a valid government-issued photo ID confirming the user's date of birth.
• Ongoing monitoring for indicators of underage account usage, with immediate suspension of any account where underage use is suspected.

ka111 reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page. Where the changes are significant, we will notify registered users via the Platform or by email before the changes take effect.

Your continued use of the Platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, please cease using the Platform and contact [email protected] to request account closure.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how your personal data is being handled, please contact our data protection team. We aim to respond to all requests within 30 days of receipt.

Email: [email protected] (plain text — not a clickable link). Please use the subject line "Privacy Rights Request" and include your registered username, the nature of your request, and any supporting details. Our team operates during Bangladesh Standard Time (BST, UTC+6) business hours, Monday to Sunday.