Privacy Policy for co111 Players in Bangladesh

01 Information We Collect

When you register for and use the co111 platform, we collect certain categories of personal information. We collect only what is necessary for the purposes described in this Privacy Policy, and we handle all data in accordance with applicable data protection principles including purpose limitation, data minimisation, and storage limitation.

1.1 Information You Provide Directly

When you create a co111 account or interact with our support team, you voluntarily provide us with personal information including:

• Full legal name and date of birth
• Residential address in Bangladesh (city, district, and postal code)
• Email address and Bangladesh mobile number
• Username and encrypted password
• Government-issued identification documents submitted during KYC verification (National Identity Card, passport, or driver's licence)
• Proof of address documents (utility bills, bank statements, or similar)
• Payment method details (bKash mobile number, Nagad account reference, Rocket wallet ID, bank account details for Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, or card details for Visa and Mastercard)
• Communications sent to co111's support team via email or live chat

1.2 Information Collected Automatically

When you access the co111 platform, certain technical information is collected automatically through our servers and analytics infrastructure:

• IP address and approximate geolocation (country, city)
• Device type, operating system, and browser version
• Session timestamps, pages visited, and time spent on each section
• Referring URL (the page or search result that brought you to co111)
• In-game activity: bet amounts, game selections, wagering patterns, and session duration
• Transaction logs: deposit and withdrawal history, payment method used, and amounts in Bangladeshi Taka (৳ BDT)

1.3 Information from Third Parties

In certain circumstances, co111 receives information about you from trusted third-party sources, including:

• Payment processors (bKash, Nagad, Rocket, Upay) who confirm the status and ownership of transactions
• Identity verification and KYC service providers who cross-reference your documents against official databases
• Fraud detection and anti-money-laundering (AML) screening services that provide risk scores and compliance alerts
• Game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) who report game session data necessary for dispute resolution

02 How We Use Your Data

co111 uses the personal information we collect for the following clearly defined purposes. We process your data only where a lawful basis exists for doing so, which includes contract performance, legal obligation, legitimate interest, or your explicit consent.

co111 does not use your personal data for automated decision-making that produces significant legal effects on you without human review. Where automated tools are used for fraud or AML screening, a co111 compliance team member reviews flagged cases before any account action is taken.

03 Sharing Your Information

co111 does not sell your personal data to third parties under any circumstances. We share your information only in the limited circumstances described below, and only with parties who are bound by appropriate data protection obligations.

3.1 Service Providers and Partners

co111 engages trusted third-party service providers who process personal data on our behalf in order to deliver the co111 platform. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and partner banks (Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank) — to facilitate deposits and withdrawals
• KYC and identity verification providers: to cross-reference documents you submit against official identity databases
• AML and fraud screening providers: to assess transaction risk and detect suspicious activity
• Game studios: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — who receive session and wager data necessary to deliver their games and resolve disputes
• Cloud hosting and infrastructure providers: who store co111's databases and application servers under strict data processing agreements
• Customer support platform providers: who power co111's 24/7 live chat and ticketing system

All service providers are contractually required to process your data only for the purposes for which it was shared, to maintain appropriate security standards, and to notify co111 promptly in the event of any data breach affecting your information.

3.2 Legal and Regulatory Disclosures

co111 may disclose your personal data to law enforcement agencies, regulatory authorities, or courts when required to do so by applicable law, court order, or governmental directive. co111 will, where legally permitted, notify you before making such a disclosure.

3.3 Business Transfers

In the event that co111 undergoes a merger, acquisition, or sale of all or part of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.

04 Cookies & Tracking Technologies

co111 uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain session security, and understand how players interact with our services. Below is a summary of the cookie categories we deploy.

co111 does not use third-party advertising or retargeting cookies. You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in and using the platform. For details on managing cookies in your specific browser (Chrome, Firefox, Safari, Edge), refer to your browser's help documentation.

05 Data Retention

co111 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:

• Account data and KYC documents: Retained for a minimum of five (5) years from the date of account closure, as required for anti-money-laundering compliance.
• Transaction records (deposits, withdrawals, wagers): Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or for five (5) years if the communication relates to a dispute, investigation, or formal complaint.
• Marketing consent records: Retained for as long as your account is active, or until you withdraw consent, whichever comes first.
• Self-exclusion records: Retained indefinitely to prevent re-registration during an active exclusion period and to support responsible gaming audits.
• Analytics and session data: Retained in anonymised or aggregated form after 24 months; identifiable session data is deleted after 12 months.

When your data reaches the end of its retention period, co111 securely deletes or anonymises it so that it can no longer be associated with your identity. Secure deletion involves overwriting stored files and purging database records in accordance with industry-standard data disposal practices.

06 Your Privacy Rights

As a co111 player, you have a number of rights in relation to the personal data we hold about you. co111 is committed to honouring these rights promptly and transparently. To exercise any of the rights listed below, contact our support team at [email protected].

6.1 Right of Access

You have the right to request a copy of the personal data co111 holds about you, including what categories of data we process, for what purposes, and with whom we share it. co111 will provide this information within 30 days of receiving a verified request.

6.2 Right to Rectification

If any personal data co111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update basic account information (email address, mobile number, residential address) directly through your co111 account settings. For corrections to identity documents or other sensitive records, contact support.

6.3 Right to Erasure

You may request the deletion of your personal data where co111 no longer has a legitimate reason to retain it. Please note that this right is subject to co111's legal obligations: data that must be retained for AML compliance, transaction records, or dispute resolution cannot be erased before the applicable retention period expires, even upon request.

6.4 Right to Restrict Processing

You have the right to ask co111 to pause or restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data is being contested, or while an objection to processing is being evaluated.

6.5 Right to Data Portability

Where processing is based on your consent or on the performance of a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, machine-readable format. co111 can provide account and transaction data in CSV format upon request.

6.6 Right to Object

You have the right to object to co111 processing your personal data for direct marketing purposes at any time. You can also object to processing based on co111's legitimate interests, though co111 may continue to process the data if there are compelling grounds that override your interests.

07 Data Security

co111 implements a layered approach to data security, combining technical, organisational, and procedural safeguards to protect your personal information against unauthorised access, loss, disclosure, alteration, or destruction. Our security measures include:

• Encryption at rest and in transit: All stored personal data is encrypted using AES-256 encryption. All data transmitted between users and co111 servers uses TLS 1.2 or higher.
• Access controls: Personal data is accessible only to co111 staff who require it to perform their job functions. All internal access is logged and subject to periodic audit.
• Two-factor authentication (2FA): co111 supports and encourages 2FA for all player accounts, using your Bangladesh mobile number for OTP verification.
• Regular security assessments: co111's platform undergoes periodic security reviews, including vulnerability scanning and penetration testing, to identify and remediate potential weaknesses.
• Incident response: co111 maintains a documented data breach response procedure. In the event of a breach affecting your personal data, co111 will notify affected players promptly and take all necessary remediation steps.

While co111 takes every reasonable precaution to protect your personal data, no internet-based system can guarantee absolute security. You play an important role in keeping your account secure: use a strong, unique password, enable 2FA, and notify co111 immediately at [email protected] if you suspect your account has been compromised.

08 Updates to This Policy

co111 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made — those that significantly affect your privacy rights or the way we process your data — co111 will notify you via the email address registered to your account at least seven (7) days before the changes take effect.

The updated Privacy Policy will always be available on this page with a revised effective date at the top. We encourage you to review this page periodically to stay informed about how co111 is protecting your information. For non-material changes (such as corrections to wording, clarifications of existing practices, or updates to contact information), the policy will be updated without advance notice.

Your continued use of the co111 platform after the effective date of any revised Privacy Policy constitutes your acknowledgement that you have read and understood the updated terms. If you do not agree with the revised Privacy Policy, you should cease using the platform and request account closure.

8.1 Contact for Privacy Queries

If you have any questions, concerns, or requests relating to this Privacy Policy or co111's data practices, please contact our support team. We are available 24 hours a day, 7 days a week, and aim to respond to all privacy-related queries within one hour during Bangladesh Standard Time (BST, UTC+6) business hours. Critical privacy matters — including suspected data breaches or urgent erasure requests — are handled around the clock.

Privacy contact email: [email protected]

This Privacy Policy was last updated on January 1, 2026 and is effective from that date. All prior versions of the co111 Privacy Policy are superseded by this document.