Privacy Policy
ax111 Platform — Data Protection Statement

1 Introduction

ax111 (referred to in this Policy as "ax111", "we", "us" or "our") operates the online gaming information platform accessible at https://ax111.cam. ax111 is an English-language informational resource targeting Pakistani users and players in permitted jurisdictions. We are committed to protecting the privacy and personal data of every individual who accesses our Platform.

This Privacy Policy (the "Policy") describes the types of personal data ax111 collects from users ("you", "your"), the purposes for which that data is used, how it is stored and protected, and the rights available to you in relation to your personal data.

By using the ax111 Platform, you acknowledge that you have read, understood and agree to the practices described in this Policy. This Policy forms part of ax111's broader legal framework alongside our Terms & Conditions and Responsible Gambling Policy.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

3 Data We Collect

ax111 collects Personal Data in several ways depending on how you interact with the Platform. The categories of data we may collect include:

3.1 Data You Provide Directly

• Registration Data: If you create an account, we collect your chosen username, email address and a hashed password. We do not store plain-text passwords.
• Support Correspondence: When you contact us by email or live chat, we collect the content of your message, your email address and any attachments you submit.
• Feedback and Surveys: If you respond to optional surveys or feedback requests, we collect the responses you provide.

3.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution and referring URL.
• Usage Data: Pages visited, time spent on each page, links clicked, scroll depth, session duration and navigation paths within the Platform.
• Cookie Data: Data stored in cookies and similar tracking technologies as described in Section 8.
• Log Data: Server logs recording access requests, error logs and security event records.

3.3 Data We Do Not Collect

ax111 does not collect payment card numbers, bank account details, cryptocurrency wallet addresses or any financial transaction data. All payment processing occurs exclusively on the operator's platform and is subject to the operator's own privacy and security controls. ax111 also does not collect biometric data, health data or sensitive personal data as defined by applicable data protection frameworks.

4 How We Use Your Data

ax111 uses Personal Data for the following purposes, each supported by an appropriate legal basis as described in Section 5:

ax111 does not use automated decision-making or profiling in a manner that produces legal or similarly significant effects on users.

5 Legal Basis for Processing

ax111 processes Personal Data on the following legal bases, consistent with internationally recognised data protection principles:

• Contract Performance: Processing necessary to provide the services you have requested, including account registration and support.
• Legitimate Interests: Processing carried out for purposes that are in the legitimate interests of ax111 or third parties, provided those interests are not overridden by your fundamental rights and freedoms. Examples include fraud prevention, platform security, analytics and service improvement.
• Legal Obligation: Processing required to comply with legal obligations applicable to ax111, including AML-related record-keeping, age verification and regulatory compliance.
• Consent: Processing carried out based on your express consent, including the use of non-essential cookies and optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Disclosure

ax111 does not sell your Personal Data. We may share your data with third parties only in the following limited and controlled circumstances:

6.1 Service Providers (Data Processors)

ax111 engages trusted third-party service providers to assist in operating the Platform, including hosting infrastructure providers, analytics platforms, email delivery services and security monitoring tools. These providers are contractually bound to process your data only on our instructions, to maintain confidentiality, and to implement appropriate security measures.

6.2 Legal and Regulatory Disclosures

ax111 may disclose Personal Data to law enforcement agencies, regulators, courts or other governmental authorities where required to do so by law, court order or binding regulatory direction. We will notify you of such disclosures where permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, reorganisation, sale of assets or similar corporate transaction, Personal Data held by ax111 may be transferred to the acquiring or successor entity, subject to that entity agreeing to honour this Policy.

6.4 Payment Method References

ax111 makes reference to familiar Pakistani payment services including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah as contextual references for users. ax111 does not share any user data with these payment providers — these references are purely informational and do not imply any data-sharing relationship, endorsement or affiliation.

6.5 No Sale of Data

Under no circumstances does ax111 sell, rent, lease or otherwise transfer your Personal Data to third parties for their own marketing or commercial purposes.

7 International Data Transfers

ax111 operates a Platform accessible from Pakistan and other jurisdictions. Personal Data collected through the Platform may be transferred to and processed in countries outside Pakistan where ax111's service providers maintain infrastructure. Such countries may have data protection laws that differ from those in Pakistan.

Where Personal Data is transferred internationally, ax111 takes steps to ensure that appropriate safeguards are in place to protect your data, including requiring contractual protections from service providers equivalent to those in this Policy.

By using the Platform, you acknowledge that your Personal Data may be transferred internationally as described above. If you have concerns about international transfers of your data, please contact us using the details in Section 15.

8 Cookies & Tracking Technologies

ax111 uses cookies and similar technologies to provide, maintain and improve the Platform experience. The following categories of cookies may be used:

You can control cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. For detailed instructions on managing cookies in common browsers, refer to your browser's help documentation.

9 Data Retention

ax111 retains Personal Data only for as long as is necessary to fulfil the purposes described in this Policy, or for as long as required by applicable law. Our general retention approach is as follows:

• Account Data: Retained for the duration of your account and for a reasonable period following account closure to allow for dispute resolution, fraud investigation or regulatory compliance requirements.
• Support Correspondence: Retained for up to 24 months from the date of the most recent communication, unless a longer period is required for an ongoing dispute or legal matter.
• Analytics Data: Aggregated and anonymised. Individual-level analytics data is retained for no longer than 26 months.
• Legal Compliance Records: Retained for the period required by applicable law, which may extend beyond account closure.
• Cookie Data: Session cookies expire when you close your browser. Persistent cookies expire at the date set in the cookie, typically between 30 days and 24 months.

When Personal Data is no longer required, ax111 will securely delete or anonymise it in a manner that prevents reconstruction of the original data.

10 Your Rights

ax111 respects your rights in relation to your Personal Data. Depending on applicable law, you may have some or all of the following rights:

To exercise any of the above rights, please contact ax111 at the address provided in Section 15. We will respond to all verified requests within 30 days. We may need to verify your identity before processing a rights request.

11 Children's Privacy

The ax111 Platform is strictly intended for adults aged 18 years and over, or the higher minimum age required by the operator's licensing jurisdiction or by the laws of the user's country of residence. ax111 does not knowingly collect Personal Data from individuals under the applicable minimum age.

If ax111 becomes aware that Personal Data has been collected from a minor without appropriate parental or guardian consent, that data will be deleted promptly. If you believe that a minor has submitted Personal Data to ax111, please contact us immediately at the address in Section 15.

12 Data Security

ax111 implements reasonable and appropriate technical and organisational security measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• Encryption: SSL/TLS encryption is applied to all data transmitted between your device and the ax111 Platform;
• Access Controls: Personal Data is accessible only to authorised personnel who need it to perform their duties, under strict access control policies;
• Password Hashing: User passwords are stored in hashed form using industry-standard algorithms. Plain-text passwords are never stored;
• Security Monitoring: ax111 employs security monitoring tools to detect anomalous access patterns and potential breaches;
• Regular Reviews: Security policies and procedures are reviewed regularly and updated in response to new threats or vulnerabilities;
• Incident Response: ax111 maintains a data breach response procedure. In the event of a breach likely to result in high risk to affected individuals, ax111 will notify affected users without undue delay where required by applicable law.

While ax111 applies these measures diligently, no method of transmission over the internet or method of electronic storage is 100% secure. Users are encouraged to use strong, unique passwords and to report any suspected account compromise immediately to [email protected].

13 Third-Party Platforms & Links

The ax111 Platform may contain references to third-party operator platforms or services. ax111 has no control over the data collection, privacy practices or security standards of third-party platforms. This Policy applies solely to ax111 and does not govern data processing by any third-party operator or payment provider.

When you leave the ax111 Platform to access an operator's website, you do so subject to that operator's privacy policy and terms of service. ax111 strongly recommends reviewing the privacy policies of any platform you access, particularly before submitting Personal Data such as KYC documents or payment information.

References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are contextual references only. They do not represent a data-sharing relationship or endorsement between ax111 and these providers.

14 Amendments to This Policy

ax111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, applicable law or technological developments. When material changes are made, ax111 will update the "Last Updated" date at the top of this page. For significant changes, ax111 may also provide notice to registered users by email or through an on-Platform notification.

Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the revised terms. We recommend reviewing this page periodically — at minimum once every three months or whenever you use the Platform after receiving a change notification.

15 Contact Us

If you have questions, concerns or requests regarding this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 10, please contact ax111 using the details below. Our support email is displayed as plain text only and is not a clickable link.