di111 Privacy Policy

1. Data We Collect

di111 collects personal data from players in Bangladesh across several categories. We collect only the data that is necessary to operate the platform safely, verify player identities, process payments, and comply with applicable anti-money laundering (AML) obligations.

1.1 Registration Data

When you create a di111 account, we collect the following information:

• Full legal name (as it appears on your government-issued identity document)
• Date of birth (to verify that you are 18 years of age or older)
• Email address and mobile phone number
• Residential address (city, district, and postal code within Bangladesh)
• Preferred username and encrypted password

1.2 Identity Verification (KYC) Data

To comply with our Know Your Customer (KYC) requirements and to prevent underage gambling and financial crime, we collect:

• Scanned copy or clear photograph of your Bangladesh National Identity Card (NID) or valid passport
• Proof of residential address (utility bill, bank statement, or equivalent document dated within the last three months)
• Proof of payment method ownership (e.g., screenshot confirming the bKash, Nagad, Rocket, or Upay number is registered in your name)
• In some cases, a selfie photograph for liveness verification purposes

1.3 Financial Transaction Data

di111 logs all deposit and withdrawal transactions processed through your account. This includes the transaction amount in BDT (৳), the payment method used (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, or City Bank), the date and time of the transaction, and the transaction reference number issued by your payment provider. di111 does not store full payment card numbers or mobile banking PINs.

1.4 Gameplay and Betting Data

di111 records information about your activity on the platform, including the games you play, bets placed, sports markets accessed, wager amounts, game outcomes, bonus activations, and session durations. This data is used to administer your account, detect fraud, meet regulatory record-keeping requirements, and improve the di111 product experience.

1.5 Technical and Device Data

When you access di111 through a browser or mobile device, our servers automatically collect certain technical information:

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser version
• Pages visited on di111.app, time spent on each page, and referring URL
• Session identifiers and cookie data (see Section 4 for full cookie details)

1.6 Customer Support Communications

If you contact di111 via email at [email protected] or through any in-platform support channel, we retain a record of the communication, including the content of your messages and any attachments. This record is used to resolve your query, improve our support quality, and maintain an audit trail of account-related decisions.

2. How We Use Your Data

di111 uses the personal data it collects for the following specific purposes:

Purpose	Data Used	Legal Basis
Account registration and management	Registration data, contact details	Contract performance
Age and identity verification (KYC)	KYC documents, date of birth	Legal obligation
Processing deposits and withdrawals	Financial transaction data, KYC data	Contract performance
Anti-fraud and anti-money laundering screening	Transaction data, device data, IP address	Legal obligation / Legitimate interest
Responsible gaming monitoring	Gameplay data, session data, deposit history	Legal obligation / Legitimate interest
Customer support resolution	Support communications, account data	Contract performance
Platform security and fraud prevention	Device data, IP address, session data	Legitimate interest
Service improvement and analytics	Aggregated technical and gameplay data	Legitimate interest
Sending account-related notifications	Email address, mobile number	Contract performance
Sending promotional communications (if opted in)	Email address, mobile number	Consent

di111 does not use your personal data to make fully automated decisions that produce legal or similarly significant effects on you without human review.

3. Data Sharing & Third Parties

di111 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We share your data only in the following limited circumstances:

3.1 Payment Service Providers

To process your deposits and withdrawals, di111 shares the minimum necessary data — including your name, mobile number, and transaction amount — with our payment processing partners. These partners include bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, and City Bank. All payment partners are contractually required to handle your data in accordance with their own published privacy policies and applicable financial regulations in Bangladesh.

3.2 Identity Verification Services

di111 may engage a third-party KYC and identity verification provider to assist in processing and validating the documents you submit. Any such provider is bound by a data processing agreement that restricts them from using your data for any purpose other than completing the verification task on di111's behalf.

3.3 Fraud Prevention and Security

di111 may share IP addresses, device fingerprints, and transaction data with industry-standard fraud prevention and AML screening platforms. This processing is carried out on the basis of di111's legitimate interest in protecting the security and integrity of the platform.

3.4 Legal and Regulatory Disclosure

di111 may disclose your personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction if required to do so by applicable law, or if we have a good-faith belief that such disclosure is necessary to prevent fraud, money laundering, or other criminal activity.

3.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of di111's business assets, player data may form part of the transferred assets. You will be notified in advance via the email address associated with your di111 account if your data is to be transferred to a new controller, and you will retain your rights over that data under the new entity.

4. Cookies & Tracking

di111 uses cookies and similar technologies (including local storage and session tokens) to operate the platform, maintain your login session, and understand how players use the site in aggregate.

4.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the di111 platform to function. These include your session authentication token and CSRF protection tokens. They cannot be disabled without breaking core platform functionality.
• Preference Cookies: Store your language preference, display settings, and last-accessed region. These make returning to di111 more convenient.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate di111.app. This helps us identify and fix usability issues. We use only first-party analytics data — no data is shared with third-party advertising networks.
• Security Cookies: Used to detect unusual session activity and protect your account from unauthorised access.

4.2 Managing Your Cookie Preferences

You may configure your browser to block or delete cookies at any time. Please be aware that disabling strictly necessary cookies will prevent you from logging in to your di111 account and using most platform features. Blocking preference or analytics cookies will not affect your ability to play games or make transactions. For instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

4.3 No Third-Party Advertising Cookies

di111 does not use third-party advertising cookies, retargeting pixels, or cross-site tracking technologies. Your browsing activity on di111.app is not shared with any advertising network, social media platform, or data broker.

5. Data Security

Protecting the personal data of di111 players in Bangladesh is a core operational priority. di111 applies the following technical and organisational security measures:

• Transport Encryption: All data transmitted between your browser or mobile device and di111.app is encrypted using 256-bit TLS (Transport Layer Security). Unencrypted HTTP connections are automatically redirected to HTTPS.
• Data Storage Encryption: Sensitive data fields — including KYC documents, NID scans, and financial records — are encrypted at rest using industry-standard AES-256 encryption.
• Access Controls: Access to player personal data within di111 is strictly role-based. Only authorised personnel who require access to perform a specific job function may view personal data, and all such access is logged and audited.
• Password Security: Player passwords are never stored in plaintext. di111 uses a strong one-way hashing algorithm with a unique per-account salt to store password credentials.
• Intrusion Detection: di111's infrastructure is monitored 24/7 for unusual activity, intrusion attempts, and data exfiltration patterns using automated alerting systems.
• Incident Response: In the event of a confirmed data breach that is likely to result in a risk to your rights, di111 will notify affected players via the email address on their account within 72 hours of becoming aware of the breach, along with guidance on protective steps you should take.

While di111 takes all reasonable steps to protect your data, no internet-based transmission or storage system can be guaranteed to be 100% secure. We encourage players to use a unique, strong password for their di111 account and to enable any additional security features offered in the account settings.

6. Data Retention

di111 retains personal data for the periods set out below. After the applicable retention period expires, data is securely deleted or irreversibly anonymised.

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years after closure	AML compliance and legal record-keeping
KYC identity documents	Duration of account + 5 years after closure	Regulatory obligation
Financial transaction records	7 years from transaction date	Financial record-keeping obligations
Gameplay and betting history	Duration of account + 3 years after closure	Dispute resolution, responsible gaming monitoring
Customer support communications	3 years from date of last interaction	Dispute resolution, quality assurance
Technical and device logs	12 months on a rolling basis	Security monitoring and fraud prevention
Marketing opt-in records	Until consent is withdrawn + 1 year	Evidence of lawful basis for marketing

Players who close their di111 accounts may request confirmation of the data deletion schedule applicable to their account by contacting [email protected]. Note that certain data must be retained for the minimum statutory periods listed above regardless of an account closure request.

7. Your Privacy Rights

di111 respects your rights over your personal data. As a di111 player, you are entitled to exercise the following rights at any time by submitting a request to [email protected]:

• Right of Access: You may request a copy of all personal data that di111 holds about you. We will provide this in a structured, commonly used format within 30 calendar days of receiving a verified request.
• Right to Rectification: If any personal data di111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. For example, if your registered address has changed, you may update it directly in your account settings or by contacting support.
• Right to Erasure: You may request that di111 delete your personal data. di111 will honour this request where it is not prevented from doing so by a legal obligation (such as the AML retention requirements described in Section 6). Where full deletion is not possible, di111 will explain which data must be retained and why.
• Right to Restrict Processing: You may request that di111 temporarily suspend its processing of your data while a rectification or objection request is being assessed.
• Right to Data Portability: You may request that di111 provide your personal data in a machine-readable format (such as JSON or CSV) so that it can be transferred to another service provider.
• Right to Object: You may object to di111's processing of your personal data where it is carried out on the basis of legitimate interest. di111 will assess the objection and cease processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where di111 processes your data on the basis of your consent (for example, to send you promotional emails), you may withdraw that consent at any time by updating your communication preferences in your account settings or by emailing [email protected]. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

To exercise any of the above rights, please send an email to [email protected] from the email address registered on your di111 account. We may ask you to complete a brief identity verification step before processing your request, to ensure that we do not disclose or delete another person's data in error.

8. Contact & Policy Updates

If you have any questions, concerns, or complaints about this Privacy Policy or about di111's data handling practices, please contact our Privacy team at: [email protected]. We will acknowledge your query within 48 hours and provide a substantive response within 14 calendar days.

di111 reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, changes to the di111 platform, or updates to applicable law. When we make material changes, we will update the "Last Updated" date at the top of this document. For significant changes that affect your rights, we will send an advance notice to your registered email address at least 14 days before the changes take effect.

We encourage you to review this Privacy Policy periodically. Your continued use of the di111 platform after any amendment constitutes your acceptance of the updated Policy.

For questions about this Privacy Policy, contact us at: [email protected]. Our support team is available 24/7 and responds in English.