bt1111 Privacy Policy — How We Handle Your Personal Data

1 Introduction

bt1111 operates an online sports betting and casino platform accessible at bt1111.app, serving the Bangladesh market. This Privacy Policy governs bt1111's practices with respect to the collection, processing, storage, and protection of personal data belonging to individuals who register accounts on, or otherwise interact with, the bt1111 platform.

bt1111 recognises that the personal data you provide to us — including your name, mobile number, payment method details, and transaction history — is sensitive information that deserves rigorous protection. This Privacy Policy is written in plain, formal English to ensure that Bangladesh players can clearly understand their rights and bt1111's obligations.

This Privacy Policy should be read alongside the bt1111 Terms & Conditions, which govern the contractual relationship between you and the platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a matter of data privacy, this Privacy Policy shall take precedence.

2 Data Controller

For the purposes of this Privacy Policy, bt1111 acts as the data controller in respect of personal data collected from Players via the bt1111 platform. As data controller, bt1111 determines the purposes for which personal data is collected and the manner in which it is processed.

All data processing activities carried out by bt1111 are conducted in accordance with the security and confidentiality standards set out in this Privacy Policy. Where bt1111 engages third-party processors to handle personal data on its behalf — for example, payment gateway providers or game platform suppliers — those processors are contractually required to process personal data only in accordance with bt1111's instructions and in compliance with applicable data protection standards.

3 Data We Collect

bt1111 collects the following categories of personal data from Players:

3.1 Registration and Identity Data

• Full legal name
• Date of birth
• Mobile phone number (primary contact and account identifier)
• Email address (where provided)
• Residential address (where required for KYC purposes)
• Nationality

3.2 Identity Verification (KYC) Data

• Government-issued identification documents (National Identity Card, passport, or birth certificate)
• Proof of address documents
• Proof of payment method ownership (e.g., screenshot of bKash or Nagad account registered in your name)
• Selfie or photograph where required to verify identity document authenticity

3.3 Financial and Transaction Data

• Deposit history including amounts, dates , and payment methods used
• Withdrawal history including amounts, dates, destination payment method, and processing status
• Betting and gaming transaction records including bet amounts, game types, odds accepted, and settlement outcomes
• Account balance history

3.4 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type
• Session duration, login timestamps, and logout timestamps
• Pages visited within the bt1111 platform and navigation patterns
• Referring URL (how you arrived at the bt1111 platform)

3.5 Communications Data

• Records of live chat conversations with bt1111 support staff
• Email correspondence between you and bt1111
• Records of any formal complaints or disputes submitted through the platform

3.6 Responsible Gaming Data

• Deposit limits, loss limits, and session time reminders you have set on your account
• Cooling-off period and self-exclusion records
• Any responsible gaming assessments or interventions applied to your account

4 How We Collect Data

bt1111 collects personal data through the following methods:

• Direct collection: Information you provide when registering your account, completing KYC verification, making a deposit or withdrawal, contacting support, or responding to promotions.
• Automated collection: Technical data such as IP addresses, device identifiers, session data, and usage patterns collected automatically when you access the bt1111 platform via cookies, web beacons, and server logs.
• Third-party sources: Information received from payment providers (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank) to confirm transaction details, and from identity verification service providers used to complete KYC checks.
• Game provider data: Game session records and RNG outcome logs received from licensed game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi as part of normal platform operations.

5 How We Use Your Data

bt1111 uses the personal data it collects for the following purposes:

bt1111 does not use your personal data for automated decision-making that produces legal or similarly significant effects on your account without human oversight. Where automated systems flag an account for review (for example, due to suspected fraudulent activity), a member of the bt1111 compliance team will review the case before any action is taken.

6 Legal Basis for Processing

bt1111 processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the contractual relationship established when you register a bt1111 account, including account management, payment processing, and bet settlement.
• Legal obligation: Processing required to comply with applicable legal obligations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and responsible gaming regulations.
• Legitimate interests: Processing carried out for bt1111's legitimate business interests, including fraud prevention, platform security, and the improvement of services, where those interests are not overridden by your privacy rights.
• Consent: Processing of your personal data for direct marketing and promotional communications, where you have provided explicit consent. You may withdraw this consent at any time by contacting bt1111 support or by adjusting your account communication preferences.

7 Data Sharing and Disclosure

bt1111 does not sell, rent, or transfer your personal data to unaffiliated third parties for their own commercial marketing purposes. Personal data is shared only in the following circumstances:

7.1 Payment Service Providers

bt1111 shares necessary financial and identity data with payment service providers — including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, and other bank transfer partners — to facilitate the processing of deposits and withdrawals. These providers receive only the minimum data required to complete the relevant transaction and are bound by their own data protection obligations.

7.2 Game Content Providers

bt1111 shares session identifiers and account-level data with licensed game content providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) to enable the delivery of their games on the bt1111 platform. These providers do not receive your full personal profile; data sharing is limited to what is technically necessary for game session management.

7.3 Identity Verification Services

bt1111 may engage third-party identity verification service providers to assist with KYC checks. These providers process your identity documents and verification data solely for the purpose of confirming your identity and age on behalf of bt1111, and are contractually prohibited from using your data for any other purpose.

7.4 Legal and Regulatory Disclosure

bt1111 may disclose personal data to law enforcement authorities, regulatory bodies, or other governmental agencies where such disclosure is required by applicable law, court order, or regulatory direction. bt1111 will, where legally permissible, notify the affected Player prior to making such a disclosure.

7.5 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of bt1111's assets, personal data held by bt1111 may be transferred to the acquiring entity as part of that transaction. Affected Players will be notified of any such transfer and of any material changes to the data processing arrangements that may result.

8 Cookies and Tracking Technologies

bt1111 uses cookies and similar tracking technologies on its platform to support core functionality, improve user experience, and analyse platform usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Required for the platform to function correctly, including maintaining your login session, storing account preferences, and enabling the sports betting and casino game interfaces. These cookies cannot be disabled without impairing platform functionality.
• Analytics cookies: Used to collect aggregated, anonymised data about how Players navigate and interact with the bt1111 platform. This data helps bt1111 identify which areas of the platform are most used, diagnose technical issues, and improve the overall player experience.
• Functional cookies: Used to remember your preferences — such as your preferred language, display settings, and recently viewed markets — to provide a personalised platform experience.
• Security cookies: Used to detect and prevent fraudulent login attempts, suspicious account activity, and automated bot traffic that could harm the integrity of the bt1111 platform.

By continuing to use the bt1111 platform after being presented with cookie information, you consent to the use of cookies as described above. You may manage or disable non-essential cookies through your browser settings; however, please note that doing so may affect the functionality of certain platform features.

9 Data Retention

bt1111 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including the performance of contractual obligations, compliance with legal requirements, and the resolution of any outstanding disputes.

The following general retention periods apply:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with applicable anti-money laundering and record-keeping obligations.
• Financial and transaction data: Retained for a minimum of five (5) years following the date of the relevant transaction, in compliance with financial record-keeping requirements.
• KYC documentation: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure.
• Technical and usage data: Retained for up to two (2) years from the date of collection, unless a longer retention period is required for security investigation or legal compliance purposes.
• Communications data: Support chat logs and email correspondence are retained for up to three (3) years from the date of the communication.
• Responsible gaming records: Self-exclusion and account restriction records are retained for a minimum of five (5) years to prevent circumvention of responsible gaming measures.

Upon expiry of the applicable retention period, bt1111 will securely delete or anonymise personal data in accordance with its internal data disposal procedures.

10 Data Security

bt1111 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the bt1111 platform is encrypted using SSL/TLS protocols, ensuring that your account credentials and payment details cannot be intercepted in transit.
• Access controls: Access to personal data within bt1111's internal systems is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and monitored.
• Secure data storage: Personal data is stored on secured servers with restricted physical and digital access. Payment card data is never stored directly by bt1111; it is handled exclusively by PCI-compliant payment processors.
• Intrusion detection: bt1111 employs active monitoring systems designed to detect and respond to unusual access patterns, brute-force login attempts, and other security threats in real time.
• Regular security review: bt1111 conducts periodic reviews of its data security infrastructure to identify and address potential vulnerabilities before they can be exploited.

While bt1111 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You also bear responsibility for maintaining the security of your own account credentials. If you believe your account has been compromised, contact bt1111 support immediately via live chat.

11 Your Privacy Rights

As a registered bt1111 Player, you hold the following rights with respect to your personal data. To exercise any of these rights, contact the bt1111 support team via live chat or email.

• Right of access: You have the right to request a copy of the personal data bt1111 holds about you, together with information about how that data is being processed.
• Right to rectification: You have the right to request correction of any personal data bt1111 holds about you that is inaccurate or incomplete. For name or date-of-birth corrections, supporting documentation may be required.
• Right to erasure: You have the right to request deletion of your personal data where bt1111 no longer has a lawful basis for retaining it. This right is subject to bt1111's legal retention obligations — data required for AML compliance, for example, cannot be deleted on request during the mandatory retention period.
• Right to restriction of processing: You have the right to request that bt1111 restricts the processing of your personal data in certain circumstances, such as where the accuracy of the data is contested or where you have objected to processing.
• Right to data portability: You have the right to request a structured, machine-readable copy of the personal data you have provided to bt1111, for the purpose of transferring that data to another service provider.
• Right to withdraw consent: Where bt1111 processes your personal data on the basis of your consent (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.
• Right to object: You have the right to object to bt1111's processing of your personal data where that processing is based on bt1111's legitimate interests, unless bt1111 can demonstrate compelling legitimate grounds that override your interests.

bt1111 will respond to all valid privacy rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 60 days, in which case bt1111 will notify you of the extension and the reason for it.

12 Children's Privacy

The bt1111 platform is strictly for adults aged 18 years and above. bt1111 does not knowingly collect personal data from individuals under the age of 18. If bt1111 becomes aware that personal data has been collected from a person under 18, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that a person under 18 in your care has registered an account on the bt1111 platform, please contact the bt1111 support team immediately via live chat or email. We will investigate and act promptly to close the account and delete any associated personal data.

13 Third-Party Services and Links

The bt1111 platform may reference third-party services — including payment providers such as bKash, Nagad, and Rocket, and game providers such as Pragmatic Play and Evolution Gaming — in the course of providing its services. These third parties operate under their own privacy policies and terms of service, which are independent of bt1111's Privacy Policy.

bt1111 is not responsible for the privacy practices of third-party services. Where you interact directly with a third-party payment provider's interface (for example, when making a bKash mobile transfer to fund your bt1111 account), that interaction is governed by the third party's own privacy policy. bt1111 encourages Players to review the privacy policies of all third-party services they interact with.

14 Changes to This Privacy Policy

bt1111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in platform practices, legal requirements, or data processing activities. When material changes are made, bt1111 will update the "Last Updated" date at the top of this page and, where appropriate, notify registered Players via the platform or by email to the registered contact address.

Your continued use of the bt1111 platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. It is your responsibility to review this Privacy Policy periodically to stay informed of any changes. The current version of the Privacy Policy is always available at bt1111.app/privacy-policy.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to bt1111's handling of your personal data, please contact our support team using any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week directly on the bt1111 platform.
• Email: [email protected] (plain text — not a clickable link)
• Response Time: Typically within 30 minutes during Bangladesh Standard Time (BST, UTC+6) business hours. Formal privacy rights requests will receive a substantive response within 30 days.

bt1111 treats all privacy-related enquiries with the highest priority. Our support team is trained to handle data access, correction, and deletion requests and will escalate any complex privacy matters to the appropriate internal team without delay.