h111 Privacy Policy – How We Protect Your Personal Data

1Data Controller

h111.club (referred to throughout this policy as "h111", "we", "us", or "our") is the data controller responsible for the personal information collected through the h111 platform. h111 determines the purposes and means of processing personal data in connection with the online casino, sportsbook, and related services provided at h111.club.

If you have any questions about how h111 processes your personal data, or wish to exercise any of your data rights, please contact us at: [email protected] (plain text – not a clickable link).

2Personal Data We Collect

h111 collects the following categories of personal data from registered Users and platform visitors:

3How We Collect Your Data

h111 collects personal data through the following channels and mechanisms:

• Direct Submission: Data you actively provide during account registration, KYC document upload, deposit and withdrawal requests, and support communications;
• Automated Technical Collection: Data collected automatically when you access h111, including IP address, device identifiers, session data, and browser information via server logs and cookies (see Section 7);
• Payment Processors: Transaction confirmation data received from JazzCash, Easypaisa, and banking partners as part of payment processing;
• Identity Verification Partners: Confirmation data from KYC service providers used to verify the authenticity of submitted documents;
• Fraud Prevention Systems: Risk signals from fraud detection services that help h111 identify unusual or potentially fraudulent account activity.

4Purposes of Processing & Legal Basis

h111 processes your personal data for the following purposes, each supported by an identified lawful basis:

4.1 Account Registration & Management

Purpose: Creating and maintaining your h111 account, authenticating your login sessions, and managing your account settings. Basis: Performance of contract – necessary to provide the Services you have registered for.

4.2 KYC Identity Verification

Purpose: Verifying your identity in compliance with h111's anti-fraud and Know Your Customer obligations prior to enabling withdrawal functionality. Basis: Legal obligation and legitimate interest in preventing fraud and financial crime.

4.3 Payment Processing

Purpose: Processing PKR deposits and withdrawals via JazzCash, Easypaisa, and other accepted payment methods; maintaining transaction records. Basis: Performance of contract; legal obligation to maintain financial records.

4.4 Responsible Gaming

Purpose: Monitoring player activity to identify potential gambling harm indicators; enforcing deposit limits, cooling-off periods, and self-exclusion where applied. Basis: Legitimate interest in player welfare; compliance with responsible gaming obligations.

4.5 Security & Fraud Prevention

Purpose: Detecting and preventing unauthorised account access, fraudulent transactions, money laundering, and prohibited activities under the Terms & Conditions. Basis: Legitimate interest; legal obligation.

4.6 Customer Support

Purpose: Responding to support queries, complaints, and account-related requests from Pakistani players. Basis: Performance of contract; legitimate interest in resolving disputes.

4.7 Communications & Marketing

Purpose: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where separately consented to, promotional communications about h111 offers. Basis: Consent for marketing; legitimate interest for transactional communications. You may withdraw marketing consent at any time via your account notification settings.

5Data Sharing with Third Parties

h111 does not sell or rent your personal data to any third party. h111 shares personal data with third parties only in the following limited circumstances:

• Payment Processors: JazzCash, Easypaisa, partner banks (HBL, UBL, Meezan Bank, Bank Alfalah), and card processing services receive the minimum data necessary to process your transactions;
• KYC Verification Providers: Identity document verification service providers receive your KYC documents solely for the purpose of authenticating your identity;
• Fraud Detection Services: Risk and fraud analytics providers may receive technical data (IP address, device fingerprint) to assist in fraud prevention;
• Game Content Providers: Third-party casino game suppliers may receive anonymised session data necessary for game delivery and technical support;
• Legal & Regulatory Authorities: h111 will disclose personal data to law enforcement or regulatory bodies when required to do so by applicable law, court order, or regulatory direction;
• Professional Advisors: Legal counsel, auditors, and compliance consultants under strict confidentiality obligations where necessary for h111's operational and legal requirements.

All third-party service providers engaged by h111 are subject to contractual data processing obligations that require them to handle your personal data securely, use it only for the specified purpose, and not share it further.

6KYC & Identity Document Data

Because h111 processes Pakistani CNIC documents and associated identity photographs as part of its KYC programme, h111 applies heightened safeguards to this category of data:

• CNIC document images and selfie photographs are stored in an encrypted document vault with access restricted to authorised compliance staff only;
• KYC documents are never used for any purpose other than identity verification and fraud prevention;
• Staff with access to KYC documents are subject to confidentiality obligations and access is logged for audit purposes;
• Verified KYC data is retained for the period required by applicable financial crime record-keeping standards, after which it is securely deleted;
• h111 does not use facial recognition technology for any purpose other than the comparison of a submitted selfie to the photograph on a submitted identity document, and only with your knowledge as part of the KYC process.

7Cookies & Tracking Technologies

h111 uses cookies and similar tracking technologies on h111.club. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the h111 login session, account authentication, and core platform functionality. These cannot be disabled without preventing platform use.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming notification settings between sessions.
• Analytics Cookies: Collect anonymised data about how Users navigate h111 to help us improve platform performance and user experience. No personally identifiable information is included in analytics data.
• Security Cookies: Support fraud detection and session security by maintaining session integrity tokens and device recognition data.

You can manage non-essential cookie preferences through your browser settings. Note that disabling certain functional cookies may affect your h111 platform experience. h111 does not use third-party advertising or tracking cookies that transmit data to advertising networks.

8Data Security

h111 implements technical and organisational security measures appropriate to the sensitivity of the data held, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and h111's servers;
• Encryption at rest for sensitive stored data including KYC documents, financial records, and password hashes;
• Access controls ensuring that staff only access personal data necessary for their specific function;
• Two-factor authentication enforced for h111 administrative system access;
• Regular penetration testing and security vulnerability assessments conducted by qualified third-party security professionals;
• Incident response procedures in place to address data security incidents promptly and notify affected Users where required.

Notwithstanding these measures, no internet transmission or electronic storage system is 100% secure. h111 cannot guarantee absolute security but commits to maintaining industry-standard protections and responding promptly to any security incidents.

9Data Retention

h111 retains personal data for as long as necessary to fulfil the purposes described in this Privacy Policy and to comply with applicable legal and compliance obligations:

• Account Data: Retained for the duration of the account's active life and for a period of 6 years following account closure, to meet anti-money laundering record-keeping requirements;
• KYC Documents: Retained for 6 years from the date of verification or account closure, whichever is later, in accordance with financial crime compliance standards;
• Transaction Records: Retained for 6 years from the date of each transaction for financial record-keeping compliance;
• Support Communications: Retained for 3 years from the date of the interaction unless the communication relates to an ongoing dispute or legal matter;
• Technical/Log Data: Retained for 12 months in rolling logs for security monitoring purposes, then deleted.

After retention periods expire, personal data is securely deleted or anonymised so that it can no longer be associated with an individual User.

10Your Data Rights

As an h111 User, you have the following rights in relation to your personal data:

• Right of Access: Request a copy of the personal data h111 holds about you;
• Right to Rectification: Request correction of inaccurate or incomplete personal data;
• Right to Erasure: Request deletion of your personal data where h111 no longer has a legal basis to retain it (subject to compliance retention obligations);
• Right to Restriction: Request that h111 restricts processing of your data while a rectification or objection request is being assessed;
• Right to Object: Object to processing based on legitimate interest, including profiling for responsible gaming monitoring;
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time.

To exercise any of these rights, please contact h111 support at [email protected] with the subject line "Data Rights Request". We will respond to verified requests within 30 days. For security purposes, h111 may require identity verification before fulfilling data access or deletion requests.

11Children's Privacy

h111 is strictly an 18+ platform. h111 does not knowingly collect personal data from any individual under the age of 18. The KYC verification process includes age verification precisely to prevent underage access.

If h111 discovers that personal data has been collected from a person under 18 years of age, that account will be immediately closed, all personal data associated with the underage account will be deleted promptly, and any balance will be refunded to the payment method on file.

If you believe that a minor has registered on h111, please report this immediately to [email protected]. h111 takes underage access reports with the highest priority.

12Updates to This Privacy Policy

h111 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, h111 will notify registered Users via the email address on their account or through a notice displayed upon h111 login.

The current version of this Privacy Policy is always available at h111.club/privacy-policy. The "Last Updated" date at the top of this document indicates when the policy was last revised. Your continued use of h111 following the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms.

13Contact & Complaints

For all privacy-related queries, data rights requests, or complaints about h111's handling of your personal data, please contact us using the details below:

• Email: [email protected] – subject line: "Privacy Query" or "Data Rights Request" (plain text, not clickable)
• Live Chat: Available 24/7 from your account dashboard after h111 login
• Response Time: Privacy-specific queries addressed within 72 hours; formal data rights requests responded to within 30 days

This Privacy Policy should be read alongside h111's Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your relationship with h111.