Privacy Policy — 111sx Editorial Platform

111sx ("we", "us", "our") operates the editorial information website accessible at 111sx.cam ("the Site", "the Platform"). This Privacy Policy ("Policy") describes how 111sx collects, processes, stores and protects information relating to individuals ("you", "your", "User") who access or interact with the Site.

We are committed to protecting your privacy. This Policy has been prepared to give you a clear, honest account of our data practices. We encourage you to read it in full. If you have any questions, the contact details in Section 16 are available to you at any time.

By using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to the practices described, please discontinue use of the Site.

In this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, IP addresses and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, 111sx is the Data Controller.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller, strictly in accordance with documented instructions.
• "Cookies" — small text files stored on your device by your browser when you visit a website, used to retain session or preference data.
• "User" — any individual who accesses or browses the Site.
• "Applicable Data Protection Law" — all legislation and regulations applicable to the processing of Personal Data in the relevant jurisdiction, including but not limited to the Prevention of Electronic Crimes Act, 2016 (Pakistan) and any other applicable data protection frameworks.

For the purposes of this Privacy Policy, the Data Controller responsible for Personal Data collected through the Site is the operator of 111sx, accessible at 111sx.cam.

Where third-party service providers (Data Processors) process data on our behalf — for example, hosting providers or analytics platforms — they do so only under written agreement and in accordance with this Policy.

111sx collects a limited and proportionate amount of data. The categories of data we may collect are described below.

4.1 Automatically Collected Technical Data

When you visit the Site, our web server and hosting infrastructure automatically record certain technical information. This is standard practice for all websites and is necessary for the Site to function correctly.

4.2 Voluntarily Provided Data

If you choose to contact us via email or any future contact mechanism on the Site, you may provide us with your name, email address and the content of your message. This data is used solely to respond to your enquiry and is not retained longer than necessary for that purpose.

4.3 Data We Do Not Collect

We explicitly do not collect the following categories of data:

• Payment card numbers, bank account details or wallet credentials.
• Government-issued identity documents (CNIC, passport numbers).
• Gambling account details, bet histories or transaction records.
• Sensitive personal data such as health information, biometric data or religious beliefs.
• Precise geolocation data.

Where applicable data protection legislation requires us to identify a legal basis for processing Personal Data, we rely on the following grounds:

• Legitimate Interests: The processing of automatically collected technical data (server logs, analytics) is carried out on the basis of our legitimate interests in operating, securing and improving the Site, provided those interests are not overridden by your privacy rights.
• Consent: Where we use non-essential cookies or analytics tools beyond basic server logging, we will seek your consent where required by applicable law.
• Contractual Necessity: Where you contact us with an enquiry, processing your contact details is necessary to respond to that communication.
• Legal Obligation: We may process or retain data where required to do so by Applicable Law, including in response to lawful requests from public authorities.

Data collected through the Site is used only for the purposes described below. We do not use your data for profiling, automated decision-making or targeted advertising.

• Site operation and maintenance: Ensuring the Site loads correctly, identifying and fixing technical errors, and maintaining server security.
• Analytics and editorial planning: Understanding which content is most useful to our Pakistani audience so we can improve the quality and relevance of our guides and analysis.
• Communication: Responding to enquiries or feedback submitted to us directly via email.
• Legal compliance: Retaining records as required by Applicable Law or responding to lawful data requests from competent authorities.
• Abuse prevention: Identifying and blocking malicious traffic, automated scraping or other activities that violate our Terms and Conditions.

111sx may use cookies and similar technologies to support Site functionality and collect anonymised usage data. The cookies we use fall into the following categories:

We do not use advertising cookies, cross-site tracking cookies or third-party cookies that transmit your browsing data to external advertisers.

You may control cookie settings through your browser. Most modern browsers allow you to refuse cookies, delete existing cookies or receive alerts before a cookie is stored. Disabling strictly necessary cookies may affect the functionality of the Site.

111sx does not sell, rent, trade or otherwise disclose your Personal Data to third parties for commercial purposes. Limited, controlled sharing may occur only in the following circumstances:

• Service Providers (Data Processors): We engage third-party providers for web hosting, content delivery and anonymised analytics. These providers act strictly on our instructions under data processing agreements and are not permitted to use your data for their own purposes.
• Legal Requirements: We may disclose data if required to do so by a court order, regulatory authority or other lawful process under Applicable Law.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of the 111sx platform, User data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.
• Safety and Security: We may disclose data to prevent fraud, protect against security threats or investigate potential violations of our Terms and Conditions.

In all cases, data shared with third parties is limited to the minimum necessary for the stated purpose. We do not share data with payment institutions such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — references to these brands on the Site are for informational context only.

As an online platform, 111sx may use hosting or infrastructure providers whose servers are located outside Pakistan. Where Personal Data is transferred internationally, we take steps to ensure that an adequate level of protection is applied to that data, consistent with the requirements of Applicable Data Protection Law.

Such measures may include contractual data processing agreements with service providers, requiring them to maintain appropriate technical and organisational security measures and to process data only in accordance with our documented instructions.

We retain Personal Data only for as long as is necessary for the purposes described in this Policy, or as required by Applicable Law.

• Server log data (including IP addresses and access timestamps): retained for up to 90 days for security and abuse-prevention purposes, then deleted or anonymised.
• Anonymised analytics data: may be retained for up to 24 months to support long-term editorial planning.
• Contact enquiry correspondence: retained for up to 12 months following resolution of the enquiry, then securely deleted.

When retention periods expire, data is securely deleted or irreversibly anonymised so that it can no longer be attributed to any individual.

Subject to Applicable Data Protection Law, you may have the following rights in relation to Personal Data we hold about you:

• Right of Access: You may request confirmation of whether we hold Personal Data about you and, if so, a copy of that data.
• Right to Rectification: You may request that inaccurate or incomplete Personal Data be corrected.
• Right to Erasure: You may request deletion of Personal Data where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal obligations.
• Right to Restriction: You may request that we restrict processing of your Personal Data in certain circumstances — for example, while the accuracy of the data is disputed.
• Right to Object: You may object to processing carried out on the basis of our legitimate interests, where your individual circumstances justify such objection.
• Right to Data Portability: Where processing is based on your consent or a contract and is carried out by automated means, you may request a copy of your data in a structured, commonly used and machine-readable format.

Please note that because 111sx collects minimal Personal Data from Site visitors, we may not hold identifiable data about you in many circumstances. Standard server log data may not be sufficient to identify a specific individual without additional information.

The 111sx platform covers topics related to gambling and online betting, which are restricted to adults. The Site is not directed at individuals under the age of 18, or the higher minimum age required by relevant operator licence jurisdictions.

We do not knowingly collect Personal Data from minors. If you believe that a minor has provided Personal Data to us without appropriate parental consent, please contact us immediately at the email address in Section 16 and we will take prompt steps to delete such data.

111sx implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• HTTPS/TLS encryption for all data transmitted between your browser and our servers.
• Access controls restricting server-level access to authorised personnel only.
• Regular review of hosting infrastructure security configurations.
• Prompt investigation and remediation of any identified security vulnerabilities.

Editorial content on 111sx may reference or describe third-party gambling platforms, payment services, sports organisations and technology providers. This Privacy Policy applies solely to data collected through the 111sx platform at 111sx.cam.

If you visit any third-party platform mentioned in our content, that platform's own privacy policy will govern the collection and use of your data. 111sx has no control over, and assumes no responsibility for, the privacy practices of any third-party site. We strongly encourage you to review the privacy policies of any platform you choose to use.

In particular, if you register with or use any gambling operator referenced in our editorial content, you will be subject to that operator's KYC/AML data collection requirements, which may include verification of your identity documents, address and source of funds — none of which data passes through 111sx.

111sx reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable legislation or the operation of the Site. When we make material changes, the effective date at the top of this page will be updated.

We encourage you to review this Policy periodically. Your continued use of the Site following the posting of any revised Policy constitutes acceptance of the updated terms. If you do not agree to a revised Policy, you should discontinue use of the Site.

If you have any questions, concerns or requests relating to this Privacy Policy or the way 111sx processes your Personal Data, please contact us using the details below. We aim to respond to all privacy enquiries within 10 working days.

Please note that we are unable to respond to enquiries relating to the data practices of third-party gambling operators or payment providers referenced in our editorial content. For those matters, please contact the respective organisation directly.