xp111 is committed to protecting the personal data of every player across Pakistan. This Privacy Policy explains exactly what information we collect, why we collect it, how we use it, and the rights you hold over your own data.
Our Commitments
These six principles underpin every data decision xp111 makes. They are not aspirational — they are binding commitments backed by the technical and organisational measures described in the full policy below.
xp111 collects personal data only for specific, explicit, and legitimate purposes. We do not repurpose your data for anything beyond what is described in this Privacy Policy without obtaining fresh consent from you first.
We collect only the data that is strictly necessary to deliver our services, comply with our regulatory obligations, and protect our players. If a piece of information is not needed, we do not collect it — full stop.
All xp111 systems are built with security as a primary requirement, not an afterthought. Your personal and financial data is protected by 256-bit SSL encryption, bcrypt password hashing, and access controls limiting who can view your records.
xp111 will never sell, rent, or trade your personal data to third parties for their own marketing purposes. Your contact details are yours — not a commodity to be packaged and sold on to advertisers or data brokers.
xp111 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. When data is no longer needed, it is securely deleted or anonymised.
You have meaningful rights over your personal data, including the right to access, correct, delete, and restrict its processing. xp111 has dedicated processes to honour these rights promptly and without unnecessary friction.
xp111 is an internationally licensed online gaming operator serving players across Pakistan, including Karachi, Lahore, Faisalabad, Islamabad, and beyond. The xp111 Platform — accessible at xp111.net — provides cricket betting, PSL markets, live casino, slot games, and fishing games including Bombing Fishing and Ocean Lord.
For the purposes of this Privacy Policy, xp111 acts as the data controller in respect of all personal data collected from players, visitors, and prospective registrants who interact with the Platform. As data controller, xp111 is responsible for determining how and why personal data is processed.
If you have any questions about how xp111 handles your personal data, you may contact our Data Protection team at any time. Contact details are provided in Section 13 of this Policy.
xp111 collects personal data across several categories, depending on how you interact with the Platform. The table below summarises the main categories of data collected and the typical source of each.
| Data Category | Examples | Source |
|---|---|---|
| Identity Data | Full name, date of birth, CNIC / passport number, gender | Provided by you during registration or KYC |
| Contact Data | Email address, phone number, city / province | Provided by you during registration or account updates |
| Financial Data | JazzCash / EasyPaisa wallet references, bank account details, transaction history, PKR balances | Provided by you during deposits or withdrawals |
| KYC Documentation | Scanned CNIC, proof of address, payment method screenshots | Provided by you during identity verification |
| Gaming Activity Data | Bet history, game sessions, wager amounts, win/loss records, bonus usage | Automatically generated by Platform activity |
| Technical Data | IP address, device type, browser, operating system, session timestamps | Automatically collected via cookies and server logs |
| Communications Data | Live chat transcripts, support emails, feedback submissions | Generated when you contact xp111 support |
| Marketing Preferences | Email/SMS opt-in status, communication preferences, promotion history | Provided by you or inferred from account activity |
xp111 uses your personal data strictly for the purposes described in this section. We do not use your data in ways that are incompatible with these stated purposes without notifying you and, where required, obtaining your consent.
We process your identity, contact, and financial data to create and manage your xp111 account, process deposits and withdrawals in PKR, settle bets and casino game outcomes, and provide customer support. Without this processing, we cannot deliver the services you have contracted with us to provide.
xp111 is required by its operating licence and applicable anti-money laundering regulations to verify the identity of all players, monitor transactions for suspicious activity, and retain certain records for mandatory periods. This processing is a legal obligation and cannot be opted out of while you hold an active xp111 account.
xp111 uses gaming activity data to monitor for indicators of problem gambling, enforce self-exclusion requests, and comply with responsible gaming requirements. This processing protects the welfare of our players and is a condition of our operating licence.
Technical data, financial data, and gaming activity data are processed by xp111's fraud prevention systems to detect and prevent unauthorised account access, bonus abuse, money laundering, and other forms of financial crime. This processing is in xp111's and players' legitimate interests.
Where you have provided consent, xp111 may use your contact data to send you information about relevant promotions, PSL betting offers, new game launches, and platform updates. You may withdraw consent at any time by contacting our support team or updating your account preferences. Withdrawal of marketing consent does not affect the lawfulness of any processing already carried out.
Aggregated and anonymised technical and gaming activity data may be used to analyse Platform performance, improve user experience, optimise game offerings, and develop new features. This data cannot be used to identify individual players.
xp111 processes personal data only where a valid legal basis exists. The primary legal bases on which xp111 relies are as follows:
xp111 does not sell, rent, or trade your personal data to any third party for their own independent commercial use. However, xp111 does share data with carefully selected categories of third parties where necessary to deliver our services or comply with legal obligations.
xp111 uses cookies and similar tracking technologies to operate the Platform, maintain your login session, remember your preferences, and analyse site performance. A summary of the cookie categories used is provided below.
These cookies are essential to the operation of the xp111 Platform. They enable core functions such as maintaining your authenticated session, processing transactions, and applying security controls. These cookies cannot be disabled without materially impairing your ability to use the Platform.
Functional cookies allow xp111 to remember your preferences — such as language settings, display options, and notification preferences — so that your experience remains consistent across visits. Disabling these cookies will result in these preferences resetting each time you visit.
xp111 uses analytics cookies to understand how players interact with the Platform — which pages are visited most frequently, where users encounter difficulties, and how navigation flows are used. This data is collected in aggregate form and is used solely to improve Platform performance. No individual player profiles are built from analytics data.
You may manage and disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the xp111 Platform. Detailed cookie management instructions are available from the help section of your browser provider.
xp111 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:
xp111 retains personal data for only as long as necessary to fulfil the purpose for which it was collected, subject to any longer retention period required by law or regulatory obligation. The key retention periods applied by xp111 are as follows:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account & Identity Data | Duration of account + 5 years post-closure | AML regulatory obligation |
| Transaction Records | 7 years from transaction date | Financial regulatory requirement |
| KYC Documentation | Duration of account + 5 years post-closure | AML & licence obligation |
| Gaming Activity Logs | 3 years from account closure | Dispute resolution & regulatory audit |
| Support Communications | 3 years from last interaction | Legitimate interests (dispute resolution) |
| Marketing Consent Records | 3 years from consent withdrawal | Legal obligation (proof of consent) |
| Technical & Session Logs | 12 months | Security monitoring & fraud detection |
Upon expiry of the applicable retention period, personal data is securely deleted from xp111 systems or, where deletion is not technically feasible, anonymised such that it can no longer be attributed to any individual.
xp111 respects your rights in relation to your personal data. The rights available to you are described below. To exercise any of these rights, contact our Data Protection team using the details in Section 13. xp111 will respond to all verifiable requests within 30 days.
You have the right to request a copy of the personal data xp111 holds about you, along with information about how it is being used, the legal basis for its processing, who it has been shared with, and how long it will be retained.
If any personal data xp111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update most contact details directly from your xp111 account settings; for changes to identity data, please contact support.
In certain circumstances you may request the deletion of your personal data. This right is not absolute — xp111 may retain data where required by law or where a legitimate interest overrides the erasure request. We will explain any applicable exceptions clearly in our response.
You may request that xp111 suspends the processing of your personal data in certain circumstances — for example, while you contest its accuracy, or while xp111 assesses an objection you have raised. Data subject to a restriction notice will not be processed beyond storage until the restriction is lifted.
Where xp111 processes your data on the basis of consent or contract, and the processing is carried out by automated means, you have the right to receive a copy of your data in a structured, commonly used, machine-readable format for transfer to another controller.
You have the right to object to processing carried out on the basis of xp111's legitimate interests or for direct marketing purposes. Where you object to direct marketing, processing for that purpose will cease immediately. Other objections will be assessed on a case-by-case basis.
The xp111 Platform is strictly intended for individuals who are 21 years of age or older. xp111 does not knowingly collect personal data from individuals under this age. If xp111 discovers that personal data has been collected from an individual under 21, that data will be deleted immediately and the associated account permanently closed.
xp111 strongly encourages all account holders who share devices with minors to enable appropriate parental controls on those devices to prevent access to the xp111 Platform by underage individuals.
xp111's primary operations serve players in Pakistan. Some of the third-party service providers engaged by xp111 — including KYC verification partners, cloud infrastructure providers, and fraud prevention platforms — may process data in jurisdictions outside Pakistan.
Where personal data is transferred internationally, xp111 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy. Safeguards employed include:
If you require further information about the specific safeguards applicable to any particular international transfer, please contact our Data Protection team.
xp111 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.
Where changes are material — meaning they substantively affect your rights or how xp111 uses your data — we will notify you via the email address registered to your account and/or via a prominent in-Platform notification, with a minimum of 14 days' notice before the changes take effect.
We encourage you to review this Privacy Policy periodically so that you remain informed about how xp111 protects your personal data. Continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.
If you have any questions, concerns, or requests relating to this Privacy Policy or the way xp111 processes your personal data, please contact our Data Protection team through any of the following channels:
If you believe xp111 has not handled your personal data in accordance with this Privacy Policy or applicable data protection law, you have the right to lodge a formal complaint. Please raise the matter first with xp111 by emailing [email protected], clearly marked as a data protection complaint. xp111 will acknowledge your complaint within 5 business days and provide a substantive response within 30 days.
If you remain dissatisfied with xp111's response, you may escalate your complaint to the relevant data protection supervisory authority in your jurisdiction, or to the independent dispute resolution body designated under xp111's operating licence. Details of the applicable authority or body will be provided upon request.
Your Data Is Safe With Us
Now that you understand how xp111 protects your personal data, you can enjoy cricket betting, PSL odds, live casino, and slots knowing your information is in safe hands. 21+ only. Play responsibly.