ko111 Privacy Policy — How We Handle Your Data

1. Introduction

This Privacy Policy ("Policy") describes how ko111 ("the Platform", "we", "us", "our") collects, uses, stores, shares, and protects personal information provided by or collected about users ("you", "your") of the ko111 website and all related services (collectively, "the Services"). This Policy applies to all players in Bangladesh and to any other person who accesses or uses the Services. By registering an account on ko111 or otherwise using the Services, you acknowledge that you have read and understood this Policy and consent to the collection and use of your information as described herein.

ko111 takes data privacy seriously. We collect only the information we need to operate the platform safely, comply with applicable obligations, and provide you with a high-quality gaming experience. We do not sell your personal data to third parties. We do not share your data with advertisers. We do not use your data for purposes beyond those described in this Policy without first obtaining your consent.

2. Our Privacy Commitments at a Glance

The following highlights summarise how ko111 approaches your data. Full details are set out in the sections below.

3. Information We Collect

ko111 collects personal information in three ways: information you provide directly when registering or using the Services; information collected automatically when you use the platform; and information received from trusted third parties involved in operating the Services (such as payment processors). The categories of information we collect are set out below.

Information You Provide Directly

• Registration information: your full legal name, date of birth, mobile number, and any other information requested during the account creation process. This information is collected to verify your identity, confirm your eligibility (including age verification to confirm you are 21 or above), and create your ko111 account.
• Verification documents: copies of government-issued identity documents (such as a National Identity Card, passport, or driving licence) and proof of address, where ko111 requires these to satisfy KYC (Know Your Customer) obligations. You provide these only when requested as part of an account verification or withdrawal review process.
• Communication records: the content of any messages you send to ko111 support, including queries submitted via email to [email protected], together with metadata about those communications (date, time, subject). These records are retained to assist with ongoing support, dispute resolution, and quality assurance.
• Voluntary profile information: any additional information you choose to add to your account profile beyond what is required for registration, such as a preferred display name or communication preferences.

Information Collected Automatically

• Device and connection information: your IP address, device type, operating system, browser type and version, mobile network operator, and screen resolution. This information is collected automatically when you access ko111 and is used for platform security, fraud detection, and technical optimisation.
• Usage and behavioural data: information about how you navigate and use the ko111 platform, including pages visited, games played, bets placed (stake amounts, game type, outcome), session duration, and click patterns. This data is used to improve the platform, personalise your experience, identify patterns of problem gambling, and detect fraudulent activity.
• Transaction data: records of all deposits and withdrawals made through your ko111 account, including the payment method used (bKash, Nagad, Rocket, Upay, or bank transfer), the amount in Bangladeshi Taka, timestamps, and transaction reference numbers. This data is retained for financial record-keeping, dispute resolution, and regulatory compliance.
• Cookie and session data: information stored in cookies and similar tracking technologies placed on your device when you use the ko111 platform. See the Cookies section of this Policy for full details.

Information From Third Parties

• Payment verification data: confirmation of transaction status and basic payment metadata received from our payment processing partners (bKash, Nagad, Rocket, Upay, and banking partners). ko111 does not receive or store your full mobile banking PIN, password, or full bank account number — those credentials remain with the payment provider.
• Identity verification results: pass or fail outcomes from identity verification checks conducted by third-party KYC service providers engaged by ko111 to verify player identities. The underlying documents are handled according to the verification provider's own security standards and are not stored indefinitely by ko111.
• Fraud and risk signals: where ko111 uses third-party fraud detection or risk assessment services, those services may provide risk scores or flags associated with account activity patterns. These signals are used solely for platform security and fraud prevention purposes.

4. How We Use Your Information

ko111 uses the personal information we collect for the following purposes. In each case, use of your information is tied to a specific, legitimate purpose and is not extended beyond what is reasonably necessary to fulfil that purpose.

• Account creation and management: to register your ko111 account, verify your identity and age (confirming you are 21 or above), manage your account settings, process your deposits and withdrawals, and maintain your transaction history.
• Service delivery and improvement: to operate the ko111 platform, provide access to games and betting markets, resolve technical issues, and improve the quality and performance of the Services based on aggregated usage data.
• Security and fraud prevention: to monitor account activity for signs of fraudulent behaviour, unauthorised access, money laundering, or other prohibited conduct; to verify the legitimacy of payment transactions; and to protect the integrity of the platform and the safety of all players.
• Responsible gaming: to monitor patterns of play that may indicate problem gambling; to implement deposit limits, self-exclusion arrangements, and time-out periods requested by players; and to fulfil ko111's commitment to player welfare. Age verification data is used to enforce the strict 21+ requirement.
• Customer support: to respond to queries, complaints, and requests submitted to ko111 support; to maintain a record of communications for quality assurance, dispute resolution, and regulatory compliance purposes.
• Legal and regulatory compliance: to comply with applicable anti-money laundering (AML) obligations, KYC requirements, and any other legal obligations applicable to ko111's operations. This may include retaining transaction records and identity verification results for the legally required minimum retention periods.

5. Legal Basis for Processing

ko111 processes your personal data only where there is a lawful basis for doing so. The legal bases on which ko111 relies are set out below.

• Contractual necessity: processing required to perform our contract with you — primarily, operating your ko111 account, processing deposits and withdrawals, and providing access to the Services you have registered to use.
• Legal obligation: processing required to comply with applicable legal requirements, including KYC identity verification, AML transaction monitoring, age verification (21+ enforcement), and retention of financial records.
• Legitimate interests: processing carried out in pursuit of ko111's legitimate business interests, where those interests are not overridden by your rights and interests. This includes platform security monitoring, fraud detection, technical performance analytics, and responsible gaming monitoring.
• Consent: where ko111 relies on your consent as the legal basis for processing (for example, for optional marketing communications), you may withdraw that consent at any time by contacting [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. Disclosure of Your Information

ko111 does not sell, rent, or trade your personal data. We share your information only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

Service Providers and Operational Partners

• Payment processing partners (bKash, Nagad, Rocket, Upay, and banking partners): your payment details are shared with the relevant payment provider solely to process your deposit or withdrawal transaction. These partners are not permitted to use your information for any other purpose.
• Identity verification and KYC providers: your identity documents and related personal information may be shared with third-party KYC service providers engaged by ko111 to conduct identity and age verification checks. These providers are bound by confidentiality obligations and data processing agreements.
• Technology and infrastructure providers: technical service providers who assist with platform hosting, data storage, security monitoring, and analytics may process your data on ko111's behalf. All such providers are required to handle your data securely and only as instructed by ko111.

Legal and Regulatory Disclosure

ko111 may disclose your personal information to law enforcement agencies, regulatory bodies, or other governmental authorities where required to do so by applicable law, court order, or where ko111 reasonably believes that disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity. Where permitted by law, ko111 will notify you of any such disclosure.

7. Payment Data and Financial Information

All financial transactions on ko111 are processed in Bangladeshi Taka (BDT) via trusted payment partners including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank. When you initiate a deposit or withdrawal, you are redirected to or interact with the relevant payment provider's interface. ko111 does not receive, process, or store your mobile banking PIN, your full bank account number, or any payment credential that you enter directly into a payment provider's system.

ko111 retains records of transaction amounts, dates, payment methods used, and transaction reference numbers associated with your account. These financial records are retained for the period necessary to comply with applicable financial record-keeping obligations and to assist with the resolution of any disputes relating to your account transactions.

8. Cookies and Tracking Technologies

ko111 uses cookies and similar technologies to operate the platform, remember your session, and understand how players use the Services. A cookie is a small text file stored on your device by your browser. ko111 uses the following categories of cookies.

• Essential cookies: these are strictly necessary for the ko111 platform to function. They maintain your login session, enable secure navigation between pages, and support core platform features. These cookies cannot be disabled without preventing the platform from working correctly.
• Analytics cookies: these help ko111 understand how the platform is being used — for example, which pages are visited most frequently, how long sessions last, and where technical errors occur. Analytics data is processed in aggregated, anonymised form and is used solely to improve the platform. ko111 does not use analytics cookies to build individual marketing profiles.
• Security cookies: short-lived cookies used to support fraud detection and session security. These help ko111 identify suspicious patterns of access and protect player accounts from unauthorised login attempts.

You can manage or disable cookies through your browser settings at any time. Please note that disabling essential cookies will affect the functionality of the ko111 platform and may prevent you from logging in or using core features. ko111 does not use third-party advertising cookies or tracking pixels for ad targeting.

9. Data Retention

ko111 retains your personal data only for as long as is necessary for the purposes for which it was collected, or for as long as required by applicable law. The specific retention periods that apply to different categories of data are as follows: account registration data and KYC verification records are retained for the duration of your account and for a minimum period after account closure as required by applicable financial regulations; transaction records (deposit and withdrawal history) are retained for the minimum period required by applicable financial record-keeping obligations; support communication records are retained for a period sufficient to resolve any ongoing disputes and to meet quality assurance requirements.

When the applicable retention period has expired, ko111 will securely delete or anonymise your personal data so that it can no longer be linked to you as an individual. Where deletion is not immediately possible (for example, because data is stored in backup archives), ko111 will isolate your data from further active processing until deletion is possible.

10. Your Rights Over Your Personal Data

You have the following rights in relation to the personal data ko111 holds about you. To exercise any of these rights, contact ko111 at [email protected]. ko111 will respond to all verifiable data rights requests within a reasonable time and will not charge a fee for standard requests.

• Right of access: you have the right to request a copy of the personal data ko111 holds about you, together with information about how it is being used. This is sometimes called a Subject Access Request (SAR).
• Right to rectification: if you believe that personal data ko111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You can update basic account information directly through your ko111 account settings; for more complex corrections, contact support.
• Right to erasure (right to be forgotten): you have the right to request that ko111 delete the personal data it holds about you, subject to ko111's legal retention obligations. Where ko111 is required by applicable law to retain certain data (for example, financial transaction records), full erasure may not be immediately possible, but ko111 will delete all data it is not legally required to retain.
• Right to restriction of processing: in certain circumstances, you have the right to request that ko111 restrict the processing of your personal data — for example, while a dispute about the accuracy of your data is being resolved, or while an objection to processing is being assessed.
• Right to object: where ko111 processes your personal data on the basis of its legitimate interests, you have the right to object to that processing. ko111 will assess your objection and will cease processing unless there are compelling legitimate grounds for the processing that override your rights.

To exercise any of the rights above, or to raise a concern about how ko111 handles your personal data, please contact [email protected] with a description of your request. Please note that ko111 may need to verify your identity before actioning a data rights request, to protect against unauthorised access to another person's data.

11. Security of Your Data

ko111 implements appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include SSL encryption for all data transmitted between your device and the ko111 platform, restricted access controls limiting who within ko111's operations can access personal data, secure data storage with access logging and anomaly detection, and regular security reviews of the platform's infrastructure.

While ko111 takes reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your ko111 account credentials. If you believe your account has been compromised, contact ko111 support immediately at [email protected] so that we can take protective action on your behalf.

12. Children and Minors

The ko111 platform is strictly for adults aged 21 and above. ko111 does not knowingly collect personal data from persons under the age of 21. If ko111 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed. If you are a parent or guardian and believe that a minor has registered on ko111 using false information, please contact [email protected] immediately so that we can investigate and take appropriate action. Age verification is a core part of the ko111 registration process and is taken seriously.

13. Changes to This Privacy Policy

ko111 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the way we operate the Services. The date at the top of this Policy indicates when it was last updated. Where changes are material, ko111 will make reasonable efforts to notify registered players — for example, by displaying a prominent notice on the platform or by contacting you at the mobile number or email associated with your account. Your continued use of the Services after the updated Policy has been published constitutes your acceptance of the updated terms. If you do not agree with the updated Policy, you should stop using the Services and may request account closure by contacting [email protected].

14. Contact and Data Enquiries

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how ko111 processes your personal information, please contact us at the email address below. ko111 support operates on Bangladesh Standard Time (BST, UTC+6) and aims to respond to all privacy-related enquiries within one business day.