dc111 Privacy Policy —
How We Protect Your Data

This Privacy Policy ("Policy") describes how dc111, operating the online casino and sports betting platform at dc111.io ("Platform"), collects, processes, stores, and protects personal data relating to individuals who access or use the Platform ("Players" or "you"). This Policy applies to all visitors, registered account holders, and any individual whose personal data dc111 processes in connection with the provision of its services.

dc111 is committed to protecting your privacy and handling your personal data with transparency, integrity, and in accordance with applicable data protection principles. By registering for a dc111 account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read in conjunction with dc111's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference and form part of the overall agreement between you and dc111.

dc111 collects personal data through several channels: directly from you during registration and account use, automatically through the Platform's technical systems, and from trusted third-party verification and payment service providers. The categories of personal data we collect are as follows:

2.1 Registration and Account Data

• Full legal name (as it appears on official government-issued identification)
• Date of birth (used to verify the 21+ age eligibility requirement)
• Residential address (including city, district, and postcode)
• Email address
• Mobile phone number (used for account communications and two-factor authentication)
• Username and encrypted password hash
• Preferred currency (Bangladeshi Taka, BDT)

2.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued identity documents, which may include: Bangladesh National Identity Card (NID), passport biographical data page, or driving licence
• Proof of address documentation (utility bill or bank statement dated within 90 days)
• Facial verification data where required by our KYC service provider to match a selfie to an identity document
• Source of funds information where required by anti-money laundering (AML) obligations

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method identifiers
• Mobile financial service account identifiers (e.g., bKash or Nagad account numbers, partially masked)
• Bank account details (where bank transfer is used) in partially masked form
• Bonus and promotional credit histories
• Wagering history and account balance records

2.4 Technical and Usage Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, browser type and version
• Session timestamps, page navigation paths, and feature interaction logs
• Game session data including games played, stakes, outcomes, and session duration
• Error logs and crash reports generated during Platform use

2.5 Communications Data

• Records of live chat conversations with the dc111 support team
• Email correspondence sent to and received from dc111 support addresses
• Feedback, complaint, and dispute records

dc111 uses the personal data it collects for the following clearly defined purposes. We do not use personal data for any purpose incompatible with those listed here without first obtaining your explicit consent.

Purpose	Data Categories Used
Account creation and management — creating and maintaining your player account, enabling login, and managing account settings	Registration data, technical data
Identity verification (KYC) — confirming your identity and age eligibility in accordance with responsible gaming obligations	KYC data, registration data
Payment processing — processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, bank transfer, and card methods	Financial data, registration data
Fraud and AML detection — detecting and preventing fraudulent activity, money laundering, and bonus abuse	All categories
Customer support — responding to queries, complaints, and disputes	Communications data, registration data, financial data
Responsible gaming — monitoring for indicators of problem gambling and applying self-imposed limits or exclusion orders	Usage data, financial data, registration data
Promotional communications — sending bonus offers, seasonal promotions, and platform updates to opted-in players	Registration data, usage data (opted-in players only)
Platform improvement — analysing aggregated usage data to improve game selection, performance, and user experience	Technical data, usage data (anonymised or aggregated)
Legal compliance — maintaining records required for legal, audit, or regulatory purposes	All categories

dc111 processes personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing that is required to fulfil dc111's obligations to you under the Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable legal obligations, including anti-money laundering (AML) record-keeping, KYC verification requirements, and responsible gaming mandates.
• Legitimate interests: Processing carried out in pursuit of dc111's legitimate business interests, including fraud prevention, security monitoring, and Platform improvement — provided these interests are not overridden by your fundamental privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent, principally for the sending of promotional and marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

dc111 uses cookies and similar tracking technologies on the Platform to ensure correct functionality, improve performance, and — where consent has been given — to deliver personalised content and promotional offers. A "cookie" is a small data file placed on your device by the Platform when you visit.

The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cookies cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Used to remember your preferences such as language setting, currency display, and game lobby filters, so that your experience is consistent across sessions.
• Analytics Cookies: Used to collect aggregated, anonymised information about how players navigate and interact with the Platform. This data is used exclusively to improve dc111's products and services. Analytics cookies are only placed where you have provided consent.
• Marketing and Personalisation Cookies: Used to deliver promotional content and bonus offers relevant to your demonstrated interests on the Platform. These cookies are only placed where you have explicitly opted into promotional communications.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies may prevent certain Platform features from working correctly. For a full list of cookies used by dc111 and their retention durations, contact our support team.

dc111 does not sell, rent, or trade your personal data to unaffiliated third parties for their independent commercial use under any circumstances. Data may be shared with carefully selected third-party service providers strictly to the extent necessary for them to perform services on dc111's behalf. All third-party providers are contractually bound to use your data only for the specified service purpose and to maintain appropriate security standards.

The categories of third parties with whom dc111 may share personal data include:

• Payment Processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard, solely for the purpose of processing deposit and withdrawal transactions. Only the minimum data required to process the transaction is shared.
• KYC and Identity Verification Providers: Third-party identity verification services used to confirm player identity, age, and source of funds where required. These providers are contractually prohibited from using KYC data for any purpose other than identity verification on dc111's behalf.
• Game Content Providers: Licensed game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive session data necessary to operate their games within the dc111 platform environment. No personally identifiable registration data is shared with game providers beyond a pseudonymous session token.
• IT Infrastructure and Security Providers: Cloud hosting, content delivery, and cybersecurity service providers who process data solely as part of operating and protecting the Platform's technical infrastructure.
• Legal and Regulatory Authorities: dc111 may disclose personal data to law enforcement agencies, financial intelligence units, or courts where required to do so by applicable law, a court order, or where dc111 has a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or harm to individuals.

dc111 retains personal data only for as long as is necessary for the purpose for which it was collected, or for as long as is required by law. The following general retention periods apply:

Data Category	Retention Period
Active account registration data	For the duration of the account's active status
Post-closure account data	5 years following account closure (audit and AML requirements)
KYC identity documents	5 years from the date of verification or account closure (whichever is later)
Financial transaction records	5 years from the date of the transaction
Support and communications records	3 years from the date of the communication
Marketing consent records	Until consent is withdrawn, then 2 years as proof of consent history
Technical and usage logs	12 months on a rolling basis, then aggregated and anonymised
Self-exclusion records	Minimum 6 years to prevent re-registration during exclusion period

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where anonymisation is applied, the resulting data set no longer constitutes personal data and may be retained for statistical or analytical purposes without limitation.

dc111 implements a comprehensive set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include but are not limited to:

• Encryption in Transit: All data transmitted between your device and dc111's servers is encrypted using TLS 1.2 or higher. The dc111 Platform operates exclusively over HTTPS, and HTTP connections are automatically redirected to HTTPS.
• Encryption at Rest: Sensitive personal data stored in dc111's databases — including identity documents, financial records, and KYC data — is encrypted at rest using AES-256 grade encryption.
• Access Controls: Access to personal data within dc111's internal systems is restricted on a strict need-to-know basis. Staff members are granted access only to the categories of data required to perform their specific role. All internal data access is logged and periodically audited.
• Two-Factor Authentication (2FA): dc111 offers players the option to enable two-factor authentication on their account, providing an additional layer of protection against unauthorised login. Players are strongly encouraged to enable 2FA through their account security settings.
• Penetration Testing and Security Audits: dc111's Platform and infrastructure undergo periodic security assessments conducted by qualified security professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: dc111 maintains a documented data breach response procedure. In the event of a data breach that is likely to result in a risk to player rights, affected players will be notified promptly with details of the nature of the breach and the steps dc111 is taking to address it.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. Players are responsible for maintaining the confidentiality of their own account credentials and for immediately reporting any suspected unauthorised access to our support team.

As a dc111 player, you hold the following rights with respect to the personal data we hold about you. To exercise any of these rights, please contact the dc111 support team via live chat in your account dashboard or by email at [email protected], clearly stating the right you wish to exercise and providing sufficient information for us to verify your identity.

• Right of Access: You have the right to request a copy of the personal data dc111 holds about you, together with information about how that data is being used. dc111 will provide this information within 30 days of a verified request.
• Right to Rectification: If any personal data dc111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. For certain data elements (such as your registered name or date of birth), updated KYC documentation may be required to process the correction.
• Right to Erasure ("Right to Be Forgotten"): In certain circumstances, you may request that dc111 delete all personal data it holds about you. This right is subject to limitations — dc111 may be required to retain certain data for legal, regulatory, or fraud-prevention purposes even following an erasure request. Where erasure is not possible in full, dc111 will inform you of the data that must be retained and the reason for retention.
• Right to Restriction of Processing: You may request that dc111 restrict the processing of your personal data in certain circumstances, for example while a rectification or objection request is being assessed. Where processing is restricted, dc111 will continue to store the data but will not actively use it pending resolution.
• Right to Data Portability: Where dc111 processes your personal data by automated means on the basis of your consent or a contract, you have the right to receive a copy of that data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to dc111's processing of your personal data where that processing is based on dc111's legitimate interests. dc111 will cease the processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on your consent (principally for marketing communications), you may withdraw that consent at any time through your account notification settings or by contacting support. Withdrawal does not affect the lawfulness of any processing that took place prior to the withdrawal.

dc111 operates a strict minimum age policy. The Platform is intended exclusively for adults aged 21 and above. dc111 does not knowingly collect personal data from individuals under the age of 21, and any account found to have been registered by a minor will be immediately suspended and all associated personal data permanently deleted.

dc111 employs age verification controls during the registration process and as part of its ongoing KYC programme to detect and prevent underage access. If you believe a minor has registered on dc111 or accessed the Platform, please contact our support team immediately at [email protected] so that the account can be closed without delay.

dc111 supports responsible gambling initiatives that include age-restriction software for household devices. Parents and guardians concerned about a minor's exposure to online gambling content are encouraged to use third-party parental control tools in addition to dc111's own age verification measures.

The dc111 Platform may contain links to third-party websites or integrate third-party content (such as game studios' embedded game interfaces). This Privacy Policy applies solely to personal data processed by dc111 in connection with the Platform. dc111 is not responsible for the privacy practices of third-party websites or service providers that operate under their own independent privacy policies.

When you interact with a third-party game interface embedded within the dc111 Platform (for example, a live dealer table operated by Evolution Gaming or a slot game by Pragmatic Play), that provider's own data processing practices may apply to the game session data generated within their interface. dc111 contractually requires all game providers to maintain data handling standards consistent with those described in this Policy, but players are encouraged to review the relevant provider's privacy documentation for complete information.

dc111 is not responsible for the content, accuracy, or privacy practices of any external website that you access by following a link from the Platform. Access to third-party sites is entirely at your own risk.

dc111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, business practices, or Platform functionality. All amendments will be published on this page with an updated "Last Updated" date visible at the top of the Policy and in the table of contents sidebar.

Where a proposed amendment is material — meaning it significantly affects the way dc111 collects, uses, or shares your personal data — dc111 will provide advance notice to registered players via email or an in-platform notification at least 14 days before the amended Policy takes effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

dc111 recommends that players review this Privacy Policy periodically to remain informed of how their personal data is being handled. If you do not agree with any amendment to this Policy, you should cease using the Platform and may request account closure by contacting our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or to dc111's data processing practices, please contact our dedicated support team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via your dc111 account dashboard. Average response time is 2–5 minutes.
• Email: [email protected] — responses within 2 business days for standard privacy queries; within 5 business days for formal data rights requests.
• Postal Address: Written correspondence related to data rights requests or formal privacy complaints may be sent to the registered business address listed in dc111's Terms & Conditions.

When submitting a data rights request or a privacy complaint by email, please include your registered dc111 username and the email address associated with your account so that we can verify your identity and locate your records promptly. Do not include your full password or payment credentials in any email communication.

dc111 takes all privacy complaints seriously and will acknowledge receipt of any formal complaint within 5 business days. If you are not satisfied with dc111's response to a privacy complaint, you may have the right to escalate the matter to a relevant data protection authority or supervisory body in your jurisdiction.