ax111 Privacy
Policy

ax111 ("we", "us", "our", or "the Company") operates the online gaming platform accessible at ax111.net, including all associated web pages, mobile interfaces, gaming products, sports betting markets, wallet services, and customer support channels. ax111 is an internationally licensed online gaming operator serving Pakistani players.

This Privacy Policy applies to all personal data collected by ax111 in connection with your use of the ax111 platform, whether you are a registered account holder, a visitor to our website, or an individual who has contacted our support team. By using any part of the ax111 platform, you acknowledge that you have read and understood this Privacy Policy.

ax111 collects the minimum personal data necessary to provide you with a safe, compliant, and high-quality gaming experience. The categories of data we collect are outlined in the table below.

ax111 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data beyond what is strictly necessary for responsible gaming assessments.

ax111 collects personal data through the following channels:

• Direct collection: Information you provide when registering an account, completing identity verification, making a deposit or withdrawal, contacting support, or participating in a promotion.
• Automated collection: Technical data collected automatically when you access or use the ax111 platform, including via cookies, server logs, and session tracking tools.
• Third-party sources: Identity verification data confirmed through licensed KYC service providers; payment data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast in connection with your transactions; fraud-prevention signals from security partners.
• Publicly available sources: In limited circumstances where required for AML compliance, ax111 may supplement your data with information from publicly available sanctions lists or politically exposed persons (PEP) databases.

ax111 uses your personal data strictly for the purposes described at the time of collection and as set out in this Privacy Policy. Our primary uses of your data are as follows:

• Account management: Creating and maintaining your ax111 account, processing your login, and managing your account preferences and security settings.
• Identity and age verification: Confirming that you are who you say you are and that you meet the 21+ age requirement before granting access to real-money gaming services.
• Payment processing: Processing PKR deposits and withdrawals via your chosen payment method, reconciling transactions, and maintaining accurate financial records.
• Gaming service delivery: Enabling you to place bets, play casino games, access your wallet, and use all other features of the ax111 platform.
• Regulatory compliance: Meeting ax111's obligations under its international gaming licence, including AML checks, responsible gaming monitoring, and regulatory reporting.
• Fraud prevention and security: Detecting and preventing fraudulent activity, unauthorised account access, multi-accounting, and other prohibited conduct as defined in our Terms & Conditions.
• Customer support: Responding to your queries, resolving disputes, and maintaining records of support interactions.
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling indicators and, where appropriate, proactively reaching out to offer assistance or apply protective limits.
• Marketing communications: Sending you promotional emails, SMS messages, or in-platform notifications about bonuses and offers — but only where you have given your consent. You may withdraw consent at any time.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the ax111 platform, gaming product offering, and user experience.

ax111 processes your personal data on one or more of the following legal grounds, depending on the specific processing activity involved:

• Contractual necessity: Processing required to fulfil our obligations to you under the ax111 Terms & Conditions — including account management, payment processing, and gaming service delivery.
• Legal obligation: Processing required to comply with ax111's obligations under its international gaming licence, applicable AML regulations, and tax reporting requirements.
• Legitimate interests: Processing carried out for ax111's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, and service improvement through aggregated analytics.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

ax111 does not sell your personal data. We share your data only in the circumstances described below, and only to the extent necessary for the stated purpose:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast receive the financial data necessary to process your deposits and withdrawals. Each provider operates under its own privacy policy and data security obligations.
• Identity verification providers: Licensed KYC and AML service providers receive your identity documents and personal details solely for the purpose of verifying your identity and screening against sanctions and PEP lists.
• Gaming content providers: Game studios and live casino operators whose products are hosted on ax111 may receive your player ID and session data for game delivery and fairness audit purposes. They do not receive your full identity or financial data.
• Regulatory and law enforcement authorities: ax111 will disclose personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or our licensing obligations — without prior notice to you where legally required.
• Fraud prevention networks: In cases of confirmed fraud, ax111 may share relevant account and transaction data with industry fraud prevention platforms to protect the wider gaming ecosystem.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of ax111's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

ax111 uses cookies and similar tracking technologies to provide a functional, secure, and personalised experience on the platform. A cookie is a small text file stored on your device when you visit a website. ax111 uses the following categories of cookies:

• Essential cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Performance cookies: Collect anonymised data about how players use the ax111 platform — such as which pages are visited most often and where errors occur — to help us improve the service. No personally identifiable information is collected by these cookies.
• Functional cookies: Remember your preferences, such as language settings, preferred games, and display configurations, so you do not have to reset them on every visit.
• Analytics cookies: Used to understand aggregate traffic patterns and player behaviour across the platform. Data is processed in anonymised, aggregated form and is not used to identify individual players.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies will affect the functionality of your ax111 account. ax111 does not use third-party advertising cookies or cross-site tracking technologies.

ax111 retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by our licensing obligations and applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your account relationship with ax111 and for a minimum period of five (5) years following permanent account closure.
• Financial and transaction records: Retained for a minimum of five (5) years in accordance with AML regulatory requirements applicable under ax111's international gaming licence.
• Identity verification documents: Retained for the period required by our licensing authority, typically five (5) years from the date of verification or account closure, whichever is later.
• Support and communication records: Retained for three (3) years following the resolution of the relevant support interaction or dispute.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the prior consent.

Upon expiry of the applicable retention period, ax111 securely deletes or anonymises your personal data in accordance with industry-standard data disposal procedures. Where anonymisation is applied, the resulting data may be retained indefinitely for statistical and analytical purposes without identifying you.

As a player on the ax111 platform, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our support team via live chat or email at [email protected] with the subject line "Data Rights Request".

• Right of access: You may request a copy of the personal data ax111 holds about you, along with information about how it is used and shared.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you. Where possible, you can update basic profile information directly in your account dashboard.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Note that data required for AML compliance or licensing purposes cannot be deleted before the applicable retention period expires.
• Right to restrict processing: You may request that we limit the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or have objected to processing.
• Right to data portability: You may request a copy of personal data you have provided to ax111 in a structured, machine-readable format.
• Right to object: You may object to processing of your personal data where ax111 relies on legitimate interests as its legal basis. You may also object to processing for direct marketing purposes at any time, which we will action immediately.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

ax111 is strictly an adult gaming platform. Registration is only permitted for individuals who are 21 years of age or older. ax111 does not knowingly collect personal data from persons under the age of 21.

All accounts are subject to mandatory age verification via CNIC or passport before real-money gaming access is granted. Where ax111 discovers that personal data has been collected from a person under 21, the account will be immediately closed, all data will be deleted to the extent permitted by law, and any deposited funds will be returned to the original payment source.

ax111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption: All data transmitted between your device and ax111's servers is encrypted using TLS 1.2 or higher.
• Data encryption at rest: Sensitive personal data, including identity documents and financial records, is stored in encrypted form using AES-256 encryption.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. ax111 staff with access to personal data are subject to confidentiality obligations and regular security training.
• Audit logging: All access to sensitive personal data is logged and subject to periodic audit review.
• Penetration testing: ax111's systems are subject to regular independent security assessments and penetration testing.
• Incident response: ax111 maintains a documented data breach response procedure. In the event of a data breach affecting your rights, we will notify you and any applicable regulatory authority within the timeframes required by our licensing obligations.

While ax111 takes all reasonable steps to protect your data, no internet-based system is completely immune to security risks. You play an important role in keeping your account secure by using a strong, unique password and by never sharing your login credentials with anyone.

ax111 operates as an internationally licensed gaming platform. As a result, your personal data may be transferred to and processed in countries outside of Pakistan, including the jurisdiction in which ax111 holds its gaming licence and the locations of our technology and service providers.

Where such transfers occur, ax111 ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses with all third-party processors that meet the standards required by ax111's licensing authority.

ax111 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via their account email address and/or via a prominent notice on the ax111 platform, with at least fourteen (14) days' notice before the updated policy takes effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how ax111 protects your data. Your continued use of the ax111 platform after the effective date of any revision constitutes your acknowledgement of the updated policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or ax111's handling of your personal data, please get in touch with our support team through any of the following channels:

• Email: [email protected] — please use the subject line "Privacy Enquiry" for data-related requests.
• Live Chat: Available 24/7 via your ax111 account dashboard — average first response under 5 minutes.
• Language: Our support team handles privacy enquiries in both Urdu and English.

For formal data rights requests — including access, rectification, erasure, or portability requests — please submit your request in writing via email with your registered account email address included in the message body. ax111 will acknowledge your request within 48 hours and provide a substantive response within 30 days.

This Privacy Policy should be read alongside ax111's Terms & Conditions and Responsible Gaming policy, both of which form part of your overall agreement with ax111.