Privacy Policy — cg111 Bangladesh

1. Overview and Scope

This Privacy Policy ("Policy") is issued by cg111 ("we", "us", "our", "the Company") and applies to all users ("you", "your", "the User") who access or use the cg111 website, platform, and associated services available at cg111.io ("the Platform"). This Policy governs the collection, use, storage, disclosure, and protection of personal data in connection with your use of cg111.

cg111 is committed to processing personal data in a lawful, fair, and transparent manner, consistent with applicable data protection principles. By registering an account, depositing funds, placing bets, or otherwise engaging with the Platform, you acknowledge that you have read and understood this Policy and consent to the data processing activities described herein.

This Policy should be read alongside cg111's Terms & Conditions and Responsible Gaming Policy. Capitalised terms used but not defined in this Policy carry the same meanings as defined in the Terms & Conditions.

2. Personal Data We Collect

cg111 collects personal data in the categories set out in the table below. We collect only data that is necessary and proportionate to the purposes for which it is processed.

Category	Examples	Purpose
Identity Data	Full name, date of birth, national ID number, photograph	Account registration, age verification, KYC compliance
Contact Data	Email address, mobile number, residential address (Dhaka, Chittagong, Sylhet, etc.)	Account communication, support, notifications
Financial Data	bKash/Nagad/Rocket/Upay mobile wallet number, Visa/Mastercard details (masked), transaction history	Deposit processing, withdrawal verification, anti-fraud
Technical Data	IP address, browser type, device ID, operating system, session tokens	Platform security, fraud detection, service optimisation
Usage Data	Pages visited, games played, bet amounts, session duration, click patterns	Service improvement, responsible gaming monitoring
Marketing Data	Communication preferences, promotion opt-ins, bonus redemption history	Personalised offers, campaign management
Communications Data	Support chat transcripts, email correspondence, complaint records	Dispute resolution, quality assurance, compliance

cg111 does not intentionally collect sensitive personal data (such as racial or ethnic origin, religious beliefs, or health information) unless this is strictly necessary for compliance purposes, in which case it will be handled with enhanced protections and will not be used for any other purpose.

3. How We Collect Your Data

cg111 collects personal data through the following channels:

• Direct interactions: Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or respond to surveys and promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, server logs, pixel tags, and similar tracking technologies (see Section 9 for cookie details).
• Third-party sources: Identity and fraud-screening data from KYC verification partners; payment confirmation data from bKash, Nagad, Rocket, Upay, Visa, and Mastercard payment processors; game activity data from licensed game studio providers including Pragmatic Play, Evolution Gaming, Spribe, and others.
• Publicly available sources: In limited circumstances, information from public registers or open data sources may be used to verify identity or assess compliance risk.

4. How We Use Your Personal Data

cg111 uses collected personal data for the following purposes:

• Account management: Creating, verifying, and maintaining your cg111 account, including processing KYC documentation and managing account security.
• Service delivery: Enabling access to casino games, sports betting markets (including BPL, IPL, T20 World Cup, football, kabaddi), live dealer tables, and all Platform features.
• Payment processing: Facilitating deposits and withdrawals through your chosen payment method (bKash, Nagad, Rocket, Upay, Visa, Mastercard) and maintaining accurate transaction records.
• Legal and regulatory compliance: Fulfilling obligations under applicable anti-money laundering, counter-terrorism financing, and data protection laws, including identity verification and transaction monitoring.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling, enforcing self-exclusion and deposit limit requests, and delivering responsible gaming communications.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, account abuse, money laundering, cheating, and other prohibited conduct.
• Customer support: Responding to enquiries, resolving disputes, and providing technical assistance via email and in-platform chat.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to users who have opted in to receive such communications. You may withdraw consent at any time by contacting our support team.
• Platform improvement: Analysing aggregated usage data to improve the performance, design, and content of the cg111 Platform.

cg111 does not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects, except where required for mandatory fraud and compliance screening, in which case you have the right to request human review of any automated decision affecting your account.

5. Legal Basis for Processing

cg111 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and cg111 — primarily account registration, game access, and payment processing.
• Legal obligation: Processing necessary to comply with applicable laws, including KYC/AML obligations and responsible gaming regulations.
• Legitimate interests: Processing carried out for cg111's legitimate business interests, such as fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Sharing Your Personal Data

cg111 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:

• Payment service providers: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and their underlying processors — to facilitate deposits and withdrawals and perform transaction verification.
• KYC and identity verification partners: Third-party services used to verify the identity and age of account holders as part of our compliance obligations.
• Game content providers: Licensed game studios (Pragmatic Play, Evolution Gaming, Spribe, Ezugi, Microgaming, NetEnt) that receive session and technical data necessary to deliver game content and resolve game disputes.
• IT and infrastructure providers: Cloud hosting, server management, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Legal and regulatory authorities: Law enforcement agencies, financial intelligence units, or regulatory bodies where we are required by law to disclose information — for example, in connection with a suspicious transaction report or a court order.
• Professional advisers: Lawyers, auditors, and accountants bound by confidentiality obligations, in connection with legal, financial, or compliance matters.

All third-party processors engaged by cg111 are contractually required to process personal data only on our documented instructions, to maintain appropriate security standards, and not to use your data for their own independent purposes.

7. Data Retention

cg111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Data Category	Retention Period	Basis
Account and identity data	Duration of account + 5 years after closure	Legal and AML compliance obligations
Financial transaction records	7 years from transaction date	Financial recordkeeping requirements
KYC verification documents	5 years after account closure	Anti-money laundering obligations
Customer support records	3 years from last interaction	Dispute resolution, quality assurance
Marketing preferences	Until consent withdrawn or account closed	Consent-based processing
Technical and usage logs	13 months from collection	Security and fraud monitoring

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where data cannot be immediately deleted due to technical constraints, it is restricted from active use until deletion is possible.

8. Security Measures

cg111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Key measures include:

• Encryption in transit: All data transmitted between your browser or device and cg111's servers is encrypted using 256-bit SSL/TLS protocols.
• Encryption at rest: Sensitive data stored on cg111's infrastructure — including financial records and KYC documents — is encrypted at rest using AES-256 encryption.
• Password security: User passwords are stored exclusively as salted cryptographic hashes. cg111 staff cannot view passwords in plain text at any time.
• Two-factor authentication (2FA): 2FA is available to all account holders and is strongly recommended as an additional layer of account security.
• Access controls: Access to personal data by cg111 staff is restricted on a strict need-to-know basis, with role-based access controls and activity logging.
• Intrusion detection and monitoring: cg111's infrastructure is protected by continuous security monitoring, automated anomaly detection, and regular third-party penetration testing.
• Data minimisation: cg111 processes only the personal data that is strictly necessary for each purpose, reducing the volume of data held and the associated risk profile.

While cg111 employs robust security measures, no digital system is entirely risk-free. You are responsible for keeping your account credentials confidential and for notifying cg111 immediately if you suspect any unauthorised access to your account.

9. Cookies and Tracking Technologies

cg111 uses cookies and similar tracking technologies on the Platform to enable essential functionality, improve performance, and (where you have consented) deliver personalised content. A cookie is a small text file placed on your device by your browser when you visit a website.

The following categories of cookies are used on cg111:

• Strictly necessary cookies: Essential to the operation of the Platform. These enable core functions such as account login, session management, and payment processing. They cannot be disabled without impairing the functionality of cg111. No consent is required for these cookies.
• Performance and analytics cookies: Collect anonymised data about how users navigate and interact with the Platform, allowing us to identify errors, measure load times, and improve the user experience. These are activated only with your consent.
• Functional cookies: Remember your preferences (such as language, currency display, and game layout settings) to personalise your experience across sessions. Activated with your consent.
• Marketing and targeting cookies: Used to track your interactions with promotional content and to measure the effectiveness of marketing campaigns. Activated only with your explicit consent.

You may manage your cookie preferences at any time through your browser settings. Most browsers allow you to refuse or delete cookies; however, disabling strictly necessary cookies may prevent some Platform features from functioning correctly. Detailed information on managing cookies is available in your browser's help documentation.

10. Your Data Rights

Subject to applicable law and certain conditions, you have the following rights in relation to the personal data that cg111 holds about you. To exercise any of these rights, please contact us at the details provided in Section 14. cg111 will respond to all verified data rights requests within 30 days of receipt.

• Right of access: You may request a copy of the personal data cg111 holds about you, along with information about how it is processed.
• Right to rectification: You may request that inaccurate or incomplete personal data be corrected or completed without undue delay.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations (such as AML retention requirements).
• Right to restriction: You may request that processing of your data be restricted in certain circumstances — for example, while a dispute about data accuracy is resolved.
• Right to data portability: Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your data in a structured, commonly used, and machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including profiling for direct marketing purposes. Where you object to marketing, we will cease processing for that purpose immediately.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to human review: Where cg111 takes an automated decision that significantly affects you, you have the right to request human review of that decision.

11. Minors and Age Restriction

cg111 strictly prohibits access by any person under the age of 21. The Platform is not directed at, and does not knowingly collect personal data from, individuals below the minimum age of 21 years. Age verification is a mandatory component of the cg111 KYC process; all account holders are required to confirm their date of birth during registration and may be required to provide supporting identification documents at any time.

If cg111 becomes aware that personal data has been collected from a person under the age of 21 without parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that your child has registered on cg111, please contact us immediately at [email protected].

12. Third-Party Services and External Links

The cg111 Platform integrates with third-party game providers, payment gateways, and analytics services as described in this Policy. Each third-party service operates under its own privacy policy and data processing terms. cg111 is not responsible for the data practices of third-party services that operate independently of our Platform.

The cg111 Platform does not contain links to external third-party websites in its navigation or content. Where reference is made to payment partners or game providers by name, this is for informational purposes only and does not constitute an endorsement of their data practices. We encourage you to review the privacy policies of any third-party service providers whose services you use in connection with your cg111 account.

13. Changes to This Privacy Policy

cg111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform functionality. Material changes to this Policy will be notified to registered users via the email address on file or by means of a prominent notice on the Platform, no less than 14 days before the revised Policy takes effect, where practicable.

Continued use of the cg111 Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. The current version of this Policy is always available at cg111.io/privacy-policy, and the version date at the top of the document identifies the operative revision.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or cg111's data processing activities, please contact our Data Support team. All privacy-related enquiries are handled in English and will receive a response within 5 business days.

Email: [email protected]
Subject line: Privacy Enquiry
Platform: cg111.io
Support Hours: 24/7 (Bangladesh Standard Time, UTC+6)