ga111 Privacy Policy

Section 1

Information We Collect

ga111 collects personal data from players through several channels: directly via the registration and account management process, automatically through your interaction with the platform, and occasionally from third-party identity verification and payment partners. The categories of personal data we collect are described below.

1.1 Registration and Account Data

When you create a ga111 account, you provide us with foundational identity information necessary to establish and manage your player account. This includes:

• Full legal name as it appears on your government-issued identification document.
• Date of birth for the purpose of verifying that you meet the minimum age requirement of 18 years.
• Country and city of residence (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi).
• Primary email address used for account communications and notifications.
• Bangladeshi mobile number used for account security and support contact.
• Username and encrypted password for platform authentication.

1.2 Identity Verification (KYC) Data

In fulfilment of our Know Your Customer (KYC) obligations, ga111 may require you to submit documentary evidence of your identity and address. KYC documents collected may include:

• Scanned or photographed copy of your Bangladesh National Identity Card (NID), valid passport, or driving licence.
• Recent utility bill, bank statement, or government correspondence as proof of residential address (dated within three months).
• Confirmation of the mobile financial service account (bKash, Nagad, Rocket, or Upay) registered in your name, or card statement for Visa/Mastercard users.

KYC documents are processed by ga111's internal compliance team and, where applicable, by our appointed third-party identity verification service provider. Documents are stored securely and accessed only by authorised personnel on a need-to-know basis.

1.3 Financial Transaction Data

To facilitate deposits and withdrawals in Bangladeshi Taka (BDT), ga111 records financial transaction data including: transaction amounts, timestamps, payment method identifiers (such as the registered bKash or Nagad mobile number, or the last four digits of a payment card), transaction reference numbers, and transaction statuses. ga111 does not store full payment card numbers, CVV codes, or mobile banking PINs.

1.4 Gaming and Betting Activity Data

ga111 records data relating to your gaming and sports betting activity on the platform. This includes game session logs, bet amounts, game outcomes, wagering history, bonus usage, and session duration. This data is used for account management, responsible gaming monitoring, dispute resolution, and fraud prevention purposes.

1.5 Technical and Device Data

When you access the ga111 platform, our systems automatically collect certain technical data about your device and connection. This includes your IP address, browser type and version, operating system, device type (desktop, mobile, or tablet), time zone setting, referring URL, and pages visited within the platform. This data is collected via server logs and cookies and is used for security monitoring, platform optimisation, and fraud detection.

1.6 Communications Data

If you contact ga111's customer support team via live chat, email ([email protected]), or WhatsApp (+880 1700 000 111), we retain records of those communications including the content of messages, the date and time of contact, and the resolution outcome. These records are maintained for quality assurance, dispute resolution, and staff training purposes.

Section 2

How We Use Your Data

ga111 uses the personal data it collects for the following specific, documented purposes. We do not use your personal data for any purpose beyond those described in this Privacy Policy without first obtaining your explicit consent.

Purpose	Data Used	Legal Basis
Account creation and management	Registration data, contact details	Contractual necessity
Age and identity verification (KYC)	KYC documents, date of birth	Legal obligation / contractual necessity
Processing deposits and withdrawals	Financial transaction data, payment method details	Contractual necessity
Fraud prevention and security	Technical data, transaction data, gaming activity	Legitimate interest
Responsible gaming monitoring	Gaming activity, session data, deposit history	Legal obligation / legitimate interest
Customer support and dispute resolution	Communications data, account data	Contractual necessity / legitimate interest
Platform improvement and analytics	Technical data, aggregated usage data	Legitimate interest
Promotional communications (with consent)	Email address, mobile number, gaming preferences	Consent

Where ga111 relies on your consent to process personal data — for example, for the purpose of sending you promotional offers, bonus notifications, or seasonal campaign communications — you may withdraw that consent at any time by updating your communication preferences in your account settings or by contacting support at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Section 3

Legal Basis for Processing

ga111 processes personal data only where a valid legal basis exists for doing so. The legal bases on which ga111 relies are as follows:

• Contractual Necessity: Processing is necessary for the performance of the agreement between ga111 and the player — including account creation, payment processing, game access, and withdrawal services. Without this processing, ga111 cannot fulfil its contractual obligations to you.
• Legal Obligation: ga111 is required to process certain categories of personal data to comply with applicable legal requirements, including anti-money laundering (AML) obligations, age verification requirements, and financial record-keeping regulations.
• Legitimate Interests: ga111 processes personal data where it has a legitimate interest in doing so, provided that interest is not overridden by the player's own privacy rights. Legitimate interest processing at ga111 includes fraud prevention, platform security monitoring, responsible gaming analysis, and internal business analytics.
• Consent: Where ga111 relies on consent as the legal basis for processing — particularly for direct marketing communications — that consent is obtained through a clear, affirmative action at the point of account registration or via subsequent opt-in. Consent is freely given, specific, informed, and unambiguous, and may be withdrawn at any time without detriment to the player's account.

Section 4

Data Sharing and Third Parties

ga111 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only with the categories of third-party service providers listed below, each of whom is engaged under contractual data protection obligations consistent with the standards set out in this Privacy Policy.

4.1 Payment Service Providers

To process deposits and withdrawals in BDT, ga111 shares relevant transaction data with payment service providers including bKash, Nagad, Rocket, Upay, and the card processing networks for Visa and Mastercard transactions. The data shared is limited to what is strictly necessary to authenticate and complete the relevant payment transaction.

4.2 Identity Verification Providers

ga111 engages specialist third-party KYC and identity verification service providers to assist in verifying the identity and age of players. These providers process KYC documents and identity data on ga111's behalf under strict data processing agreements. Verification data is not retained by the third-party provider beyond the period required to complete the verification task.

4.3 Game Studios and Content Providers

Game studios such as Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, and Spribe may receive limited technical session data (such as a pseudonymised player identifier and session token) to facilitate gameplay. These studios do not receive your full name, contact details, or financial data, and are contractually prohibited from using session data for any purpose other than delivering their respective game services.

4.4 Analytics and Platform Infrastructure

ga111 uses third-party infrastructure and analytics tools to operate, monitor, and improve the platform. These providers may process technical and aggregated usage data in the course of providing their services. Where such providers process personal data, they do so as data processors under ga111's instructions and are not permitted to use that data for their own independent purposes.

4.5 Regulatory and Law Enforcement Disclosure

ga111 may disclose personal data to regulatory bodies, law enforcement agencies, or other government authorities where required to do so by applicable law, court order, or regulatory direction. In such cases, ga111 will disclose only the minimum data necessary to satisfy the legal requirement and will, where legally permissible, notify the affected player of the disclosure.

Section 5

Cookies and Tracking Technologies

ga111 uses cookies and similar tracking technologies to ensure the platform operates correctly, to remember your session preferences, to detect and prevent fraudulent activity, and to understand how players navigate and use the platform. A cookie is a small text file stored on your device by your web browser when you visit a website.

5.1 Types of Cookies Used

• Strictly Necessary Cookies: These cookies are essential for the ga111 platform to function. They enable core features such as user authentication, session management, and security token validation. The platform cannot operate correctly without these cookies, and they do not require your consent to be set.
• Functional Cookies: These cookies remember your preferences and settings (such as your preferred language and display options) to provide a personalised experience. They persist between sessions so that your preferences are retained on return visits.
• Analytical Cookies: ga111 uses anonymised analytical cookies to understand aggregate player behaviour on the platform — for example, which game categories are most frequently visited and which support pages are accessed most often. This data is used solely to improve platform design and content. Analytical cookies do not identify individual players.
• Security Cookies: These cookies support ga111's fraud detection and account security systems by tracking anomalous session behaviour, device fingerprinting signals, and login pattern irregularities. They are strictly necessary for platform security.

5.2 Managing Cookies

You may control the setting of cookies through your browser settings. Most modern browsers allow you to block or delete cookies, or to receive a notification when a new cookie is set. Please be aware that disabling strictly necessary cookies will impair or prevent access to core ga111 platform functionality, including the ability to log in and maintain an authenticated session. Disabling analytical or functional cookies will not prevent you from using the platform but may affect the quality of your personalised experience.

Section 6

Data Retention and Deletion

ga111 retains personal data only for as long as is necessary to fulfil the specific purpose for which it was collected, to comply with applicable legal retention obligations, or to defend against potential legal claims. The retention periods applicable to the main categories of personal data processed by ga111 are set out below.

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years	AML compliance and dispute resolution
KYC identity documents	Duration of account + 5 years	Legal and regulatory obligation
Financial transaction records	Duration of account + 7 years	Financial record-keeping obligations
Gaming and betting activity logs	Duration of account + 3 years	Responsible gaming and dispute records
Customer support communications	3 years from date of last contact	Quality assurance and dispute evidence
Technical and device logs	13 months from collection	Security monitoring and fraud detection
Marketing consent records	Until consent withdrawn + 3 years	Demonstration of consent compliance

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised and aggregated data (from which no individual can be identified) may be retained indefinitely for statistical and analytical purposes.

Where a player submits a verified data deletion request (see Section 8 — Your Privacy Rights), ga111 will process that request in accordance with applicable law. Note that certain categories of data (particularly KYC documents and financial transaction records) may be subject to mandatory minimum retention periods under applicable law, during which deletion requests cannot be fully fulfilled. In such cases, ga111 will inform the player of the specific retention obligation and the earliest date on which full deletion can be carried out.

Section 7

Data Security Measures

ga111 takes the security of player personal data seriously and implements a range of technical and organisational measures designed to protect data against unauthorised access, accidental loss, destruction, or alteration. These measures include, but are not limited to, the following:

• TLS/SSL Encryption in Transit: All data exchanged between your browser or device and the ga111 platform is transmitted over HTTPS using current TLS protocols, preventing interception of data in transit.
• Encryption at Rest: Sensitive personal data stored on ga111 servers — including KYC documents, financial transaction records, and authentication credentials — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to systems containing personal data is restricted to authorised personnel only, based on the principle of least privilege. All internal access to player data is authenticated, logged, and subject to periodic access review.
• Password Hashing: Player passwords are never stored in plain text. ga111 uses strong, salted cryptographic hashing algorithms to store password credentials so that even in the event of a database compromise, raw passwords cannot be recovered.
• Security Monitoring: ga111's infrastructure is subject to continuous automated security monitoring for anomalous activity, intrusion attempts, and data exfiltration indicators. Security incidents are escalated according to a defined internal incident response procedure.
• Penetration Testing: ga111 conducts periodic third-party security assessments and penetration tests to identify and remediate potential vulnerabilities in the platform's infrastructure and application code.

Notwithstanding these measures, no system connected to the internet can be guaranteed to be completely secure. In the event that ga111 becomes aware of a data security incident that is likely to result in a risk to the rights and freedoms of affected players, ga111 will take prompt remedial action and notify affected players of the incident without undue delay, providing information about the nature of the breach and the steps being taken in response.

Section 8

Your Privacy Rights

As a registered player on the ga111 platform, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact the ga111 support team via live chat or by email at [email protected]. ga111 will acknowledge all privacy rights requests within 5 business days and will respond substantively within 30 calendar days.

• Right of Access: You have the right to request a copy of the personal data that ga111 holds about you. ga111 will provide this in a clear, structured format free of charge. Requests that are manifestly unfounded or excessive may be subject to a reasonable administrative fee.
• Right to Rectification: If any personal data ga111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay. You may also update certain account details directly within your ga111 account settings.
• Right to Erasure: You may request that ga111 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. Erasure requests are subject to the mandatory retention periods described in Section 6.
• Right to Restrict Processing: You may request that ga111 restrict the processing of your personal data in certain circumstances — for example, while a rectification request is being assessed, or where you contest the lawfulness of ga111's processing of your data.
• Right to Data Portability: Where ga111 processes your personal data on the basis of your consent or contractual necessity, and that processing is carried out by automated means, you have the right to receive your data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to ga111's processing of your personal data where that processing is based on legitimate interests. ga111 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where ga111 processes your personal data on the basis of your consent (for example, for direct marketing communications), you may withdraw that consent at any time without penalty. Withdrawal does not affect the lawfulness of prior processing.

ga111 will never penalise a player for exercising their data privacy rights. Exercising any of the rights above will not result in account closure, reduced service access, or any other adverse consequence, except to the extent that the exercise of the right necessarily impacts a service that depends on the relevant data (for example, a deletion of KYC data would necessarily prevent withdrawal processing pending re-verification).

Section 9

Minors and Privacy

The ga111 platform is strictly intended for adults aged 18 and above. ga111 does not knowingly collect personal data from individuals under the age of 18. The age verification mechanisms built into ga111's registration and KYC process are specifically designed to prevent access by minors.

If ga111 discovers or has reasonable grounds to believe that personal data belonging to a person under 18 has been collected — whether through misrepresentation of age at registration or any other means — ga111 will immediately suspend the relevant account, delete the personal data associated with the under-age individual to the extent permitted by applicable law, and take steps to ensure that any funds deposited are returned to the source payment method where technically feasible.

If you are a parent or guardian and believe that your child may have registered on ga111, please contact our support team immediately at [email protected] with the subject line "Minor Account Report". ga111 treats such reports with the highest priority and will investigate and respond within 24 hours of receipt.

Section 10

Changes to This Policy

ga111 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or the structure of the ga111 platform. The "Last Updated" date displayed at the top of this page will be revised whenever a material change is made to the Policy.

Where changes to this Privacy Policy are material — meaning they alter the nature of the data we collect, introduce new processing purposes, or affect your privacy rights in a significant way — ga111 will notify registered players via the email address associated with their account and/or via a prominent notice on the platform. ga111 recommends that all players review this Privacy Policy periodically to remain informed of how their data is being handled.

Continued use of the ga111 platform following notification of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes made to this Policy, you should cease using the platform and contact [email protected] to request account closure and the exercise of any applicable data rights before discontinuing use.

For any questions, concerns, or requests relating to this Privacy Policy or ga111's data processing practices, please contact the ga111 privacy team at: [email protected]. Please include the subject line "Privacy Enquiry" to ensure your message is routed to the appropriate team member. ga111 is committed to responding to all privacy-related enquiries within five business days.