ct111 Privacy Policy

1. Introduction

ct111 ("we", "us", "our") operates the online casino and sports betting platform accessible at ct111.org. As the data controller for personal information collected through this platform, ct111 is committed to handling all player data responsibly, transparently, and in accordance with applicable data protection standards.

By registering an account with ct111, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this Privacy Policy, you should not create an account or use the ct111 platform.

This Privacy Policy applies to all players registered on ct111, all visitors to the ct111 website, and all individuals who interact with ct111 through customer support channels including live chat and email. It applies regardless of the device or location from which you access the platform — whether you're in Karachi, Lahore, Islamabad, or elsewhere.

2. Data We Collect

2.1 Registration Data

When you create a ct111 account, we collect the following personal information:

• Full legal name as it appears on your CNIC
• Date of birth (to verify age eligibility — 18+ only)
• Pakistani mobile number
• Email address
• Residential address
• Username and encrypted password

2.2 Identity Verification (KYC) Data

To comply with anti-money laundering requirements and responsible gaming obligations, ct111 may request and retain copies of:

• National Identity Card (CNIC) — front and back
• Proof of address (utility bill or bank statement dated within 90 days)
• Proof of payment method ownership (e.g., screenshot of JazzCash or Easypaisa account linked to your registered mobile number)

2.3 Transaction and Financial Data

ct111 records all deposit and withdrawal transactions associated with your account. This includes transaction amounts in PKR, the payment method used (e.g., JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, debit card, USDT TRC20, Skrill, or Neteller), timestamps, and transaction reference numbers. ct111 does not store full card numbers — card payments are tokenised through our payment processor.

2.4 Usage and Behavioural Data

We automatically collect technical and behavioural data when you use the ct111 platform, including:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Pages visited, games played, and betting activity
• Session duration and login timestamps
• Referral source (how you arrived at ct111.org)

2.5 Customer Support Data

When you contact ct111 via live chat or email, we retain records of those communications including the content of messages, timestamps, and any resolution notes. This data is used to resolve disputes, improve support quality, and maintain records of account-related decisions.

3. How We Use Your Data

ct111 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your ct111 player account
• Identity Verification: To confirm your eligibility to participate (18+ age verification and KYC compliance)
• Payment Processing: To facilitate PKR deposits and withdrawals via JazzCash, Easypaisa, and bank transfer channels
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and Terms violations
• Customer Support: To respond to queries, resolve disputes, and communicate account-related decisions
• Responsible Gaming: To monitor gambling behaviour for signs of problem gambling and to enforce player-requested limits, cooling-off periods, and self-exclusion measures
• Marketing Communications: To send promotional offers and bonus notifications — only where you have provided explicit consent and have not opted out
• Legal Compliance: To fulfil obligations under applicable anti-money laundering, financial reporting, and data protection regulations
• Platform Improvement: To analyse usage patterns and improve the ct111 product, game lobby, cashier experience, and customer support quality

4. Legal Basis for Processing

ct111 processes your personal data under one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform the ct111 Terms and Conditions agreement with you — including account management, payment processing, and game delivery
• Legal Obligation: Processing is required to comply with anti-money laundering regulations, age verification requirements, and financial reporting obligations
• Legitimate Interests: Processing is necessary for fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights
• Consent: For marketing communications, personalised promotions, and non-essential cookies — processing is based on your explicit consent, which may be withdrawn at any time

5. Payment Data & KYC

ct111 operates a Know Your Customer (KYC) process to verify the identity of players prior to withdrawal processing. This process is a standard requirement in responsible gaming environments and is designed to protect players and the platform against fraud and financial crime.

KYC documents submitted to ct111 — including CNIC copies and proof of address — are stored in an encrypted document management system with access restricted to authorised compliance personnel only. KYC documents are not shared with game providers, marketing partners, or any other third party unless required by law.

Payment transaction data associated with JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and other payment methods is processed through ct111's payment processors, who maintain their own data security standards. ct111 does not retain full card numbers or mobile wallet PIN codes — these are processed and tokenised by the payment gateway directly.

6. Cookies & Tracking Technologies

ct111 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit ct111.org. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for login session management, security, and core platform functionality. These cannot be disabled without impairing your ability to use ct111.
• Performance Cookies: Collect anonymised data about how players use ct111 — which games are most visited, page load times, error rates — used exclusively to improve the platform.
• Functional Cookies: Remember your language preferences, game lobby filters, and display settings to personalise your ct111 experience.
• Marketing Cookies: Used with your consent to deliver relevant promotional offers. You may opt out of marketing cookies at any time via your account preferences or browser settings.

You can manage cookie preferences through your browser settings. Disabling cookies may affect the functionality of certain parts of the ct111 platform.

7. Data Sharing & Third Parties

ct111 may share your personal data with the following categories of third parties, strictly on a need-to-know basis:

• Payment Processors: JazzCash, Easypaisa, and banking partners (HBL, UBL, Meezan Bank, Bank Alfalah) receive transaction data necessary to process your PKR deposits and withdrawals
• Game Providers: Licensed game studios that supply casino games to ct111 may receive anonymised gameplay data for technical support purposes — they do not receive your identity or payment information
• KYC and Fraud Detection Partners: Identity verification and fraud prevention service providers who assist ct111 in meeting compliance obligations
• Regulatory Authorities: Where required by applicable law, regulation, or court order, ct111 may be required to disclose player data to competent authorities
• Technology Infrastructure Providers: Cloud hosting, database management, and security service providers who process data on ct111's behalf under strict data processing agreements

All third parties with whom ct111 shares personal data are contractually bound to use that data only for the specified purpose and to maintain data security standards no less stringent than those applied by ct111.

8. Data Retention

ct111 retains personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy, subject to the following minimum retention periods:

• Account registration data and KYC documents: retained for a minimum of 5 years following account closure, in line with anti-money laundering record-keeping standards
• Transaction records: retained for a minimum of 5 years following the date of each transaction
• Customer support communication logs: retained for 3 years from the date of the interaction
• Marketing consent records: retained for the duration of your account and for 2 years following account closure or consent withdrawal

After the applicable retention period expires, personal data is securely deleted or anonymised in a manner that prevents reconstruction of individual identities.

9. Data Security

ct111 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ct111 servers
• Encrypted storage of all personal data and KYC documents at rest
• Role-based access controls ensuring only authorised personnel can access player data
• Tokenisation of payment credentials — ct111 does not store raw card numbers or mobile wallet credentials
• Regular security audits and penetration testing of the ct111 platform infrastructure
• Incident response procedures for the detection, containment, and notification of data breaches where required by law

While ct111 takes all reasonable steps to secure your data, no internet-based platform can guarantee absolute security. Players are encouraged to use strong, unique passwords and to enable any available two-factor authentication features on their ct111 account.

10. Your Rights

As a ct111 player, you have the following rights in relation to your personal data:

• Right of Access: You may request a copy of all personal data ct111 holds about you at any time
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held on your account
• Right to Erasure: You may request deletion of your personal data, subject to overriding legal retention obligations (e.g., AML record-keeping requirements)
• Right to Restrict Processing: You may request that ct111 limit the processing of your data in certain circumstances
• Right to Data Portability: You may request your personal data in a structured, machine-readable format
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing
• Right to Object: You may object to processing of your data based on ct111's legitimate interests, subject to applicable exceptions

To exercise any of the above rights, contact the ct111 support team via live chat or by emailing [email protected]. ct111 will respond to all rights requests within 30 calendar days of receipt.

11. Children's Privacy

12. Changes to This Privacy Policy

ct111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in data processing practices, regulatory requirements, or platform functionality. Material changes will be communicated to registered players via email notification and/or a prominent notice displayed upon login.

The effective date of the most recent revision is displayed at the top of this page. Continued use of the ct111 platform following notification of an updated Privacy Policy constitutes your acceptance of the revised terms. Players who do not agree to the updated Privacy Policy should close their account and request deletion of their data.

13. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or ct111's data processing practices, please contact the ct111 Data Protection team through the following channels:

• Live Chat: Available 24/7 from your ct111 account dashboard — the fastest channel for privacy-related requests
• Email: [email protected] (plain text — not a clickable link)

ct111 acknowledges all privacy-related enquiries within 48 hours and provides a substantive response within 30 calendar days. For complaints that cannot be resolved directly with ct111, you may have the right to escalate the matter to a relevant supervisory authority depending on your jurisdiction.