hi111 Privacy Policy — How We Handle Your Data

Introduction

This Privacy Policy applies to all users of the hi111 platform, accessible at hi111.club, including its mobile web interface and any related services. hi111 operates as a data controller with respect to personal data collected through the platform. By registering an account or using any part of the hi111 platform, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy may be updated from time to time. The "Last Updated" date at the top of this page indicates when the most recent revision was made. We will notify registered users of material changes via the email address associated with their account or via a prominent notice on the hi111 platform. Your continued use of the platform after a change has been communicated constitutes acceptance of the revised Privacy Policy.

Section 1

Information We Collect

hi111 collects personal data through several channels: at the point of account registration, during platform use, through payment processing, and via automated technical means. The categories of personal data we collect are set out below.

Section 2

How We Use Your Information

hi111 processes personal data only for the purposes described in this Privacy Policy. We do not use personal data for automated decision-making that produces legal or similarly significant effects on users without human review. The primary purposes for which we process your personal data are:

• Account registration and management: creating and maintaining your hi111 player account, verifying your identity, and administering your account balance, betting activity, and communications preferences.
• Payment processing: facilitating deposits and withdrawals via bKash, Nagad, Rocket, and Upay; reconciling transactions; and investigating and resolving payment disputes or errors.
• Legal and regulatory compliance: performing age verification, KYC checks, and anti-money-laundering screening; retaining records as required by applicable law; and responding to lawful requests from authorities.
• Platform security and fraud prevention: monitoring account activity for signs of fraud, collusion, bonus abuse, money laundering, or prohibited conduct; and protecting the integrity of the platform for all users.
• Service improvement: analysing aggregated and anonymised usage data to understand how the platform is used, identify performance bottlenecks, and prioritise product improvements that benefit Bangladesh users.
• Marketing communications: sending you promotional offers, seasonal bonuses, and platform updates by email, where you have consented to receive marketing communications. You may withdraw consent at any time by contacting [email protected].

Section 3

Legal Basis for Processing

hi111 processes personal data on one or more of the following legal bases, depending on the nature of the processing activity.

Section 4

Sharing Your Personal Data

hi111 does not sell, rent, or trade personal data. We share personal data with third parties only in the circumstances described below, and only to the extent necessary for the relevant purpose.

• Payment processing partners: Mobile wallet providers including bKash, Nagad, Rocket, and Upay receive transaction data necessary to process deposits and withdrawals. These providers operate under their own privacy policies and are subject to applicable financial regulations.
• Game and technology providers: Certified game providers including Evolution Gaming, Pragmatic Play, Ezugi, Spribe, and Microgaming receive session and wagering data necessary to deliver game services and resolve game disputes.
• Identity verification and fraud prevention services: Third-party KYC and anti-fraud service providers may receive identity document details and account data for the purpose of age and identity verification and fraud screening. These providers are contractually bound to process data only for specified purposes.
• Law enforcement and regulatory authorities: hi111 may disclose personal data to government bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or lawful regulatory demand. hi111 will notify affected users of such disclosures where permitted to do so by law.

Section 5

Cookies and Tracking Technologies

hi111 uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device by your browser when you access hi111. They serve essential functions for platform operation, including maintaining your login session, storing your language preference, and enabling secure payment flows. Without essential cookies, the hi111 platform cannot function correctly.

hi111 may also use analytical cookies to understand aggregate usage patterns — for example, which pages are most frequently visited and how users navigate between sections. Analytical cookies do not identify individual users. hi111 does not use advertising cookies or share cookie data with advertising networks.

Section 6

Data Retention

hi111 retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. In general, account data and gaming records are retained for a minimum of five years following account closure to satisfy anti-money-laundering record-keeping requirements and to enable dispute resolution. Financial transaction records are retained for the period required by applicable financial regulations.

Where data is retained beyond the active account period for compliance purposes, hi111 applies additional access restrictions to minimise the risk of unnecessary exposure. Personal data that is no longer required and not subject to a retention obligation will be securely deleted or anonymised. You may request information about the specific retention period applicable to your data by contacting [email protected].

Section 7

Data Security

hi111 implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. No method of data transmission over the internet is 100% secure, and hi111 cannot guarantee absolute security. However, we maintain the following protections as standard across the platform.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected users, hi111 will notify affected users without undue delay and take all reasonable steps to contain and remediate the breach. If you suspect that your hi111 account has been compromised, contact [email protected] immediately and change your password.

Section 8

Your Data Rights

As a user of hi111, you have the following rights with respect to the personal data we hold about you. To exercise any of these rights, please contact [email protected] with your account details and a clear description of your request. hi111 will respond within 30 days of receiving a valid request.

• Right of access: You may request a copy of the personal data hi111 holds about you. We will provide this in a commonly used electronic format within 30 days of your request, subject to identity verification.
• Right to rectification: If you believe that personal data hi111 holds about you is inaccurate or incomplete, you may request that it be corrected. Where correction is not technically possible (for example, for historical transaction records), hi111 will add a note of the inaccuracy to your account record.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (for consent-based processing), or where processing is unlawful. This right does not apply where hi111 is required to retain data by law.
• Right to restriction of processing: You may request that hi111 restrict the processing of your personal data in certain circumstances — for example, while a dispute about data accuracy is pending, or where you have objected to processing on the grounds of legitimate interests.
• Right to data portability: Where processing is carried out by automated means on the basis of your consent or for the performance of a contract, you may request that hi111 provide your personal data in a structured, commonly used, machine-readable format so that you may transfer it to another service provider.

hi111 will not charge a fee for handling data rights requests unless a request is manifestly unfounded or excessive. In such cases, hi111 may charge a reasonable administrative fee or decline to act on the request, and will notify you of the reason in writing.

Section 9

Children's Privacy

The hi111 platform is strictly for users aged 21 and above. hi111 does not knowingly collect personal data from individuals under the age of 21. The platform employs automated and manual age-verification controls at registration. If hi111 discovers that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed without delay.

Section 10

International Data Transfers

hi111 primarily processes personal data within servers located in secure data centre facilities. Where personal data is transferred to or accessed by service providers located outside Bangladesh — for example, certified game providers or KYC verification services — hi111 ensures that appropriate safeguards are in place. These safeguards include contractual data processing agreements that require the recipient to maintain data protection standards equivalent to those applied by hi111. By using the hi111 platform, you acknowledge that your personal data may be processed in locations outside Bangladesh where different data protection laws may apply, and that hi111 has taken reasonable steps to ensure your data is adequately protected in those locations.

Section 11

Changes to This Privacy Policy

hi111 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the structure of our platform. When we make material changes, we will update the "Last Updated" date at the top of this page and notify registered users via their registered email address or via a prominent notice on the platform. Minor clarifications or corrections that do not affect your rights or our core data practices may be made without specific notification.

Your continued use of the hi111 platform after a revised Privacy Policy has been communicated constitutes your acceptance of the updated policy. If you do not agree with the changes, you should stop using hi111 and may request account closure by contacting [email protected]. Any outstanding account balance will be returned to you in accordance with our standard withdrawal procedures.

Section 12

Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or want to report a privacy concern, please contact the hi111 support team. We aim to acknowledge all privacy-related queries within 2 business hours and to resolve substantive requests within 30 calendar days.