ko111 Privacy Policy
— How We Protect Your Data

1.1 Data We Do Not Collect

ko111 does not collect biometric data (facial recognition, fingerprints, retinal scans) beyond what may be embedded in a government-issued identity document submitted for KYC purposes. We do not collect sensitive data relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, health information (other than self-reported responsible gaming disclosures), or sexual orientation. If you voluntarily include any such information in a free-text support message, it will be retained only in the context of your support record and will not be used for profiling, targeting, or any other purpose.

1.2 Data Collected from Minors

The ko111 platform is strictly for adults aged 18 and above. ko111 does not knowingly collect or process personal data from individuals under the age of 18. If we discover or are notified that data has been collected from an individual who is under 18, we will permanently close the associated account and delete all personal data relating to that individual as promptly as technically possible. If you believe a minor has registered an account on ko111, please contact us immediately at [email protected].

2.1 Provision of Services

The primary purpose for which ko111 processes your personal data is to provide you with the services you have requested — including account registration and management, processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, making available cricket betting markets (BPL, IPL, T20 World Cup, and other fixtures), and providing access to our full library of 1,200+ casino games including slots, live casino tables, WM Live, and Fierce Fishing.

Without the minimum personal data outlined in Section 1, ko111 cannot create or maintain an account for you, process financial transactions, or verify your age and identity as required under our responsible gaming obligations.

2.2 Compliance and Legal Obligations

ko111 is required to process certain personal data to comply with its legal and regulatory obligations. This includes conducting KYC (Know Your Customer) identity verification, performing anti-money laundering (AML) checks, maintaining transaction records for audit purposes, and responding to lawful requests from government authorities or courts of competent jurisdiction. Data processed for compliance purposes is retained for the minimum period required by applicable law and is not used for any secondary commercial purpose.

2.3 Security and Fraud Prevention

ko111 uses technical and account activity data to monitor for, detect, and prevent fraud, cheating, multi-accounting, bonus abuse, and unauthorised account access. Automated systems analyse login patterns, device fingerprints, and betting behaviour to flag anomalies for manual review by our compliance team. Where a potential security incident is detected, the relevant account may be temporarily suspended while an investigation is conducted. Players are notified of any such suspension via their registered mobile number or email address.

2.4 Customer Support

When you contact ko111 customer support, we use your identity data, account activity data, and the content of your communication to resolve your query. Support communications are retained for up to 24 months to allow follow-up queries to be handled with full context and to support quality assurance reviews. Support transcripts are never shared with third parties for commercial purposes.

2.5 Marketing Communications (Opt-In Only)

If you have opted in to marketing communications during registration or via your account notification settings, ko111 may send you promotional messages by SMS or email. These may include information about new games, seasonal promotions (such as Eid, Pohela Boishakh, or IPL match-day offers), bonus credits, and platform updates. You may withdraw your marketing consent at any time by updating your preferences in the account settings panel or by contacting support. Withdrawal of marketing consent does not affect transactional and security communications, which are sent regardless of marketing preference as they are necessary for account operation.

2.6 Platform Improvement

Aggregated, anonymised technical and usage data is used by ko111 to analyse platform performance, identify navigation pain points, optimise game loading speeds, and improve the overall user experience. This analysis is conducted at the aggregate level and does not involve making decisions about individual players based on their behavioural profile.

3.1 Payment Processors

To process deposits and withdrawals, ko111 shares the minimum required financial and identity data with our payment processing partners — including bKash, Nagad, Rocket, Upay, and card network processors for Visa and Mastercard transactions. These partners receive only the data that is technically required to execute the transaction and are bound by their own data protection obligations. ko111 does not store full card numbers or mobile banking PINs; these are handled exclusively by the respective payment provider.

3.2 Game Providers

ko111's game library is powered by third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. When you launch a game, a session token and anonymised player identifier are passed to the relevant provider to initialise the game session. Your full name, mobile number, and financial details are not shared with game providers. Game session data (bets placed, game rounds played, outcomes) is reported back to ko111 by the provider for balance management and responsible gaming monitoring purposes.

3.3 Identity Verification Services

For KYC verification, ko111 may use third-party identity verification services to cross-reference submitted documents against government-issued identity databases. Documents submitted for KYC are transmitted to these services over encrypted channels and are retained by the provider only for the duration required to complete the verification check. Providers are contractually prohibited from using your identity documents for any purpose other than verifying their authenticity on ko111's behalf.

3.4 Legal and Regulatory Disclosure

ko111 will disclose personal data to government authorities, law enforcement agencies, or courts of competent jurisdiction where required to do so by law, or where such disclosure is necessary to protect the rights, property, or safety of ko111, its players, or the general public. Where legally permitted, ko111 will notify the affected player of any such disclosure request before complying with it.

3.5 Business Transfers

In the event that ko111's business or assets are acquired by, merged with, or transferred to another entity, player personal data held by ko111 may be disclosed to the prospective acquirer as part of due diligence proceedings, subject to confidentiality obligations. In the event that a transfer is completed, affected players will be notified via their registered email address or mobile number and given the opportunity to request deletion of their data before the transfer takes effect if they do not wish their data to be held by the new entity.

Cookies are small text files stored on your device by your web browser at the instruction of the ko111 platform. They do not contain executable code and cannot carry viruses or malware. Most modern browsers allow you to view, manage, and delete cookies via the browser's settings menu. Please note that disabling strictly necessary or security cookies will prevent you from logging in to your ko111 account or using the platform's transactional features.

ko111 does not use third-party advertising cookies or cross-site tracking cookies. We do not share cookie data with advertising networks or social media platforms for retargeting purposes.

5.1 Active Accounts

While your ko111 account is active, ko111 retains all personal data associated with your account, including identity data, contact data, financial transaction records, and account activity data. This data is necessary to provide you with uninterrupted access to services, process transactions correctly, and maintain your responsible gaming settings and history.

5.2 Closed Accounts

When a ko111 account is closed — whether at the player's request or by ko111 following a terms violation — ko111 is required to retain certain categories of data for a defined period after closure:

• Financial transaction records (deposit history, withdrawal history, bet records): retained for a minimum of five (5) years from the date of the last transaction, as required for financial record-keeping purposes.
• Identity and KYC documents (NID copy, passport copy, proof of payment method): retained for a minimum of five (5) years from account closure.
• Support communications: retained for twenty-four (24) months from the date of the last communication.
• Technical and analytics data (IP logs, device identifiers, session logs): retained for twelve (12) months from account closure, after which they are anonymised and aggregated or deleted.
• Marketing consent records: retained for five (5) years from the date consent was given or withdrawn, to demonstrate compliance in the event of a regulatory inquiry.

After the applicable retention period has elapsed, personal data is securely deleted or irreversibly anonymised such that it can no longer be linked to any individual. Data that has been anonymised may be retained indefinitely for statistical and platform improvement purposes.

5.3 Data Storage Location

ko111 player data is stored on servers located within secure data centre facilities. Regardless of the physical server location, ko111 applies consistent data protection standards — including encryption at rest, role-based access controls, and regular third-party security audits — to all stored personal data. Transfers of personal data to third-party processors (such as payment processors and KYC service providers) are conducted over encrypted channels and governed by contractual data processing agreements that impose equivalent data protection obligations on the receiving party.

The security measures ko111 currently employs include, but are not limited to:

• TLS 1.3 encryption on all data in transit between your browser and the ko111.app servers.
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial records.
• Two-factor authentication (2FA) available to all players, providing an additional layer of account security beyond a username and password.
• Role-based access controls (RBAC) limiting employee access to player data on a strict need-to-know basis. Support agents can access only the account fields necessary to resolve your query.
• Web Application Firewall (WAF) and DDoS mitigation protecting the ko111.app platform from network-level attacks.
• Automated anomaly detection monitoring login patterns, transaction volumes, and device fingerprints to flag potentially fraudulent activity in real time.
• Periodic penetration testing conducted by independent security professionals to identify and remediate vulnerabilities before they can be exploited.

Despite these measures, no online platform can guarantee absolute security against all possible threats. In the unlikely event of a data breach that poses a risk to players' rights and freedoms, ko111 will notify affected players via their registered contact details without undue delay and will take immediate steps to contain and remediate the breach.

Players are reminded that account security is a shared responsibility. You should use a strong, unique password for your ko111 account, enable 2FA, and never share your login credentials with any other person. Report any suspected unauthorised access to your account immediately by contacting [email protected].

7.1 Right of Access

You have the right to request a copy of all personal data that ko111 holds about you. This is sometimes called a Subject Access Request (SAR). To submit a SAR, email [email protected] with the subject line "Data Access Request" and include your registered mobile number for identity verification. ko111 will respond within thirty (30) calendar days of receiving a valid request and will provide the data in a commonly used, machine-readable format (such as PDF or CSV) where technically feasible.

7.2 Right to Rectification

If any personal data that ko111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Minor corrections (such as a misspelled name) can be made by contacting support directly. Corrections to identity-critical fields (such as date of birth) may require submission of a supporting document to verify the correct information before the update is applied.

7.3 Right to Erasure

You may request that ko111 delete your personal data — sometimes called the "right to be forgotten". ko111 will action a deletion request where the data is no longer necessary for the purpose it was collected, where you have withdrawn consent and there is no other lawful basis for retention, or where the data has been processed unlawfully. Please note that ko111 is legally required to retain certain financial and identity records for a minimum of five (5) years following account closure (see Section 5.2), and deletion requests cannot override these statutory retention obligations. Once the mandatory retention period has passed, data will be deleted in full.

7.4 Right to Restriction

You may request that ko111 restrict the processing of your personal data in certain circumstances — for example, while an inaccuracy you have flagged is being investigated, or where you have objected to processing and a determination is pending. During a restriction period, ko111 will continue to store your data but will not actively process it beyond what is required for storage and security purposes.

7.5 Right to Data Portability

Where ko111 processes your personal data on the basis of your consent or to perform a contract with you, and the processing is carried out by automated means, you have the right to receive a copy of that data in a structured, commonly used format for the purpose of transferring it to another service provider. Contact support to submit a portability request.

7.6 Right to Object to Marketing

You have an unconditional right to object to the processing of your personal data for direct marketing purposes at any time. Once an objection is received, ko111 will cease all marketing communications to you within five (5) business days. This right does not apply to transactional communications (account confirmations, deposit receipts, withdrawal notifications, security alerts) which are sent on the basis of contract performance rather than marketing consent.

7.7 Exercising Your Rights

To exercise any of the rights described in this section, contact ko111 in writing at [email protected]. Please include your registered mobile number, a brief description of the right you are exercising, and any relevant details to help us locate and process your request efficiently. ko111 will acknowledge your request within three (3) business days and will complete the action within thirty (30) calendar days. If additional time is required for complex requests, ko111 will notify you of the extended timeframe and the reason for the delay. There is no fee for exercising your data rights under normal circumstances.

Whenever a material change is made to this Privacy Policy — meaning a change that affects how your personal data is collected, used, stored, or shared in a way that is meaningfully different from the previous version — ko111 will notify active players via the registered email address or mobile number at least seven (7) calendar days before the revised policy takes effect. The notification will summarise the nature of the change and provide a link to the full updated policy on the ko111.app website.

Non-material changes — such as minor clarifications of existing practices, corrections of typographical errors, or reorganisation of sections without substantive content change — may be made without advance notice. The "Effective Date" at the top of this policy will always reflect the date of the most recent revision, whether material or non-material.

Continued use of the ko111 platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you should close your ko111 account before the effective date of the change. Account closure requests submitted for this reason will be processed as a priority, and any Real-Money Balance will be refunded to your registered payment method before the account is closed.

All previous versions of this Privacy Policy are archived and can be made available upon written request to [email protected]. If you have any questions about the content of this policy or about how ko111 handles your personal data, please do not hesitate to contact our support team — available 24/7 at all hours, Bangladesh Standard Time (UTC+6).

This Privacy Policy was last updated on 1 January 2026 and supersedes all prior versions.