bt111 Privacy Policy

1 Introduction

1.1  bt111 ("we", "us", "our") is committed to protecting and respecting the privacy of all individuals who use the bt111 online betting and casino platform ("the Platform"). This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by bt111.

1.2  The bt111 Platform is operated as an internationally based service and is made available to eligible players in Bangladesh. Our primary audience consists of adult players (aged 21 and above) located across Bangladesh, including major cities such as Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar.

1.3  This Privacy Policy governs all personal data collected through the bt111 website at bt111.io, our mobile-optimised web interface, and any communications between you and bt111 through email, live chat, or other support channels. This policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy.

1.4  We take our data protection obligations seriously. bt111 employs industry-standard technical and organisational measures to safeguard your personal information against unauthorised access, accidental loss, alteration, or disclosure.

2 Personal Data We Collect

2.1  bt111 collects personal data from you in the following ways: directly when you register an account or interact with the Platform; automatically when you access and use the Platform; and from third-party verification and payment providers where necessary to complete a transaction or verify your identity.

2.2 Registration and Account Data

When you register a bt111 account, we collect the following information:

• Full legal name as it appears on your government-issued identity document
• Date of birth (to verify that you meet the 21+ age requirement)
• Mobile phone number registered in Bangladesh
• Email address (where provided)
• Preferred payment method (bKash, Nagad, Rocket, Upay, or bank account details)
• Username and encrypted password credential
• City or district of residence within Bangladesh

2.3 Identity Verification Data

To comply with anti-money laundering (AML) obligations and to verify your eligibility to use the Platform, bt111 may request the following documents at the time of registration, at first withdrawal, or at any point during your account lifecycle:

• National Identity Card (NID) number and a copy of the NID document
• Passport (where the NID is unavailable or insufficient for verification purposes)
• Birth certificate
• Proof of address (such as a utility bill, bank statement, or mobile operator statement dated within the last three months)
• Source of funds documentation (such as a payslip, bank statement, or business income evidence) where a withdrawal exceeds ৳10,000 or where unusual account activity is detected

2.4 Transaction and Financial Data

bt111 records all financial transactions conducted through your account, including:

• Deposit amounts, dates, times, and the payment method used (bKash, Nagad, Rocket, Upay, or bank transfer)
• Withdrawal requests, amounts, processing dates, and destination payment method
• Bet and wager history, including stake amounts, odds accepted, game titles, and settlement outcomes
• Bonus credits received, wagering progress, and bonus expiry events
• Account balance history

bt111 does not store complete mobile wallet PIN codes, full bank card numbers, or internet banking passwords. Payment credentials are processed through the respective payment provider's secure systems (bKash, Nagad, Rocket, Upay) and are not retained on bt111's servers beyond what is required for transaction reference.

2.5 Technical and Usage Data

When you access the bt111 Platform, we automatically collect certain technical information, including:

• Your IP address and approximate geographic location derived from it
• Device type, operating system, and browser version
• Pages visited, features used, session duration, and navigation patterns within the Platform
• Date and time of each Platform access
• Referral source (how you arrived at the bt111 Platform)
• Cookie identifiers and session tokens (see Section 6)

2.6 Communications Data

If you contact bt111's support team by email or live chat, we retain a record of that correspondence, including your contact details, the content of your messages, and any attachments you provide. This data is used to resolve your query, improve our support quality, and maintain a record of your interaction history with bt111.

3 How We Use Your Personal Data

3.1  bt111 uses the personal data we collect for the following specific purposes:

3.2  bt111 does not use your personal data to make fully automated decisions that produce legal or similarly significant effects on you, without any human review. Where automated systems flag an account for review (for example, on suspicion of fraudulent activity), the matter is reviewed by a member of the bt111 compliance team before any consequential action is taken.

4 Legal Basis for Processing Personal Data

4.1  bt111 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is required to perform the contract between you and bt111 — in particular, creating your account, verifying your identity, processing your deposits and withdrawals, and settling your bets.
• Legal Obligation: Processing that is required for bt111 to comply with applicable legal requirements, including anti-money laundering (AML) regulations, know-your-customer (KYC) obligations, and responsible gaming requirements.
• Legitimate Interests: Processing that is necessary for bt111's legitimate business interests — such as fraud prevention, platform security, and improving the player experience — provided that those interests are not overridden by your data protection rights.
• Consent: Processing for which you have given explicit, informed consent — most notably, the sending of promotional communications. You may withdraw consent at any time by contacting bt111 support at [email protected].

4.2  Where bt111 relies on legitimate interests as the legal basis for processing, we conduct a balancing assessment to confirm that our interests do not override your fundamental rights and freedoms. You have the right to object to processing based on legitimate interests — see Section 9 for details.

5 Data Sharing and Third-Party Disclosure

5.1  bt111 does not sell your personal data to any third party under any circumstances. We share your data only in the limited circumstances described in this section.

5.2 Payment Processors

To process your deposits and withdrawals, bt111 shares the minimum necessary payment information with the relevant payment service providers, including bKash, Nagad, Rocket, Upay, and partner banks (Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank). These providers receive only the data required to complete your requested transaction and are contractually obligated to process it securely and solely for that purpose.

5.3 Identity Verification Providers

bt111 may use third-party KYC (know-your-customer) and AML (anti-money laundering) verification services to cross-reference your identity documents and personal details. These providers operate under strict data processing agreements with bt111 and are not permitted to use your data for any purpose beyond the verification request.

5.4 Game Content Providers

Third-party game studios — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — provide game content to the bt111 Platform. These providers may receive your session token and anonymised gameplay data for the purpose of operating and auditing the game sessions you participate in. They do not receive your full identity data, payment details, or contact information.

5.5 Legal and Regulatory Disclosure

bt111 may disclose your personal data to law enforcement agencies, regulatory bodies, or other governmental authorities where required to do so by applicable law, by court order, or where such disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity. bt111 will endeavour to notify you of any such disclosure where permitted by law.

5.6 Business Transfers

In the event that bt111 undergoes a merger, acquisition, or sale of all or part of its business assets, your personal data may be transferred to the successor entity as part of that transaction. bt111 will notify affected players prior to any such transfer and will ensure that the successor entity provides equivalent privacy protections.

6 Cookies and Tracking Technologies

6.1  bt111 uses cookies and similar tracking technologies to operate the Platform, improve your experience, and understand how players interact with our services. By using the bt111 Platform, you consent to the use of cookies as described in this section.

6.2 Types of Cookies Used

• Essential Cookies: Required for the Platform to function correctly. These include session authentication tokens, security identifiers, and load-balancing cookies. The Platform cannot be used without these cookies; they do not require your consent.
• Functional Cookies: Remember your preferences and settings, such as your preferred language, display settings, and recent game history within a session, to provide a more personalised experience.
• Analytics Cookies: Collect anonymised data about how players navigate the Platform — which pages are visited most frequently, where users exit the site, and how long sessions last. This data helps bt111 improve Platform design and content. Analytics data is processed in aggregate and does not identify individual players.
• Security Cookies: Detect and prevent fraudulent login attempts, account takeover attacks, and unusual access patterns. These cookies are essential to the security of your account and operate without requiring separate consent.

6.3 Managing Cookies

You may control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies via their privacy settings menus. Please note that disabling certain categories of cookies may affect the functionality of the bt111 Platform — in particular, functional cookies support features such as maintaining your login state across pages.

6.4  bt111 does not use third-party advertising cookies, behavioural tracking pixels, or cross-site tracking identifiers that serve advertisements outside the bt111 Platform. Our cookies are confined to bt111.io and its direct subdomains.

7 Data Retention

7.1  bt111 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. The following retention periods apply:

7.2  Where you request deletion of your personal data under Section 9, bt111 will delete or anonymise your data within 30 days of receiving your verified request, except where retention is required to comply with a legal obligation, to resolve an open dispute, or to enforce our Terms & Conditions.

7.3  After the applicable retention period has expired, bt111 will securely delete or irreversibly anonymise your personal data so that it can no longer be associated with your identity.

8 Data Security

8.1  bt111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or destruction. These measures include:

• Transport Layer Security: All data transmitted between your device and the bt111 Platform is encrypted using TLS 1.2 or higher, with 256-bit SSL certificates, to prevent interception during transit.
• Encryption at Rest: Sensitive personal data stored on bt111's servers — including identity document data, contact details, and financial records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within bt111's internal systems is restricted on a strict need-to-know basis. Staff members are granted access only to the data necessary to perform their specific role. All data access events are logged and audited.
• Password Security: Player account passwords are stored using one-way cryptographic hashing with salt. bt111's systems do not store your password in a reversible form. Even in the event of a data breach, your raw password would not be exposed.
• Intrusion Detection: bt111 operates continuous intrusion detection and monitoring systems across its infrastructure to identify and respond to potential security threats in real time.
• Regular Security Audits: bt111 conducts periodic security assessments and penetration testing of its Platform infrastructure to identify and remediate vulnerabilities before they can be exploited.

8.2  Despite these measures, no data transmission over the internet and no data storage system can be guaranteed to be 100% secure. If you have reason to believe that your bt111 account has been compromised, you should change your password immediately and contact bt111 support at [email protected] without delay.

8.3  In the event of a personal data breach that poses a risk to your rights and freedoms, bt111 will notify affected players as soon as reasonably practicable after becoming aware of the breach, and will take immediate steps to contain and remediate the incident.

9 Your Data Protection Rights

9.1  As a player registered with bt111, you have the following rights in respect of your personal data. To exercise any of these rights, please contact bt111's support team at [email protected] with the subject line "Data Rights Request". bt111 will respond to all verified requests within 30 days.

• Right of Access: You have the right to request a copy of all personal data that bt111 holds about you. We will provide this in a structured, commonly used, machine-readable format where technically feasible.
• Right to Rectification: If any personal data that bt111 holds about you is inaccurate or incomplete, you have the right to request that we correct or complete it without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request that bt111 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where the data has been unlawfully processed. This right is subject to legal retention obligations (see Section 7).
• Right to Restriction of Processing: You may request that bt111 restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing based on legitimate interests pending bt111's assessment of that objection.
• Right to Data Portability: Where bt111 processes your data on the basis of consent or contractual necessity, and that processing is carried out by automated means, you have the right to receive your data in a portable format and to request that it be transferred to another controller where technically feasible.
• Right to Object: You have the right to object at any time to the processing of your personal data where bt111 relies on legitimate interests as the legal basis. You also have an absolute right to object to the use of your data for direct marketing purposes, which bt111 will honour immediately upon receipt of such an objection.
• Right to Withdraw Consent: Where bt111 processes your data on the basis of your consent (in particular, for promotional communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to the withdrawal.

10 Children's Privacy and the 21+ Rule

10.1  The bt111 Platform is strictly intended for individuals aged 21 years and above. bt111 does not knowingly collect personal data from any individual under the age of 21. The 21+ age restriction is enforced through our registration process and identity verification requirements, which require players to provide proof of age before they can deposit funds or place bets.

10.2  If bt111 becomes aware that it has inadvertently collected personal data from an individual who is under 21 years of age, we will immediately suspend the relevant account, delete all associated personal data, and — where applicable — refer the matter to the appropriate authorities. Any balance in such an account, including winnings, will be forfeited in accordance with our Terms & Conditions.

10.3  Parents and guardians who believe that a minor in their care has accessed or registered with bt111 should contact us immediately at [email protected]. bt111 takes such reports seriously and will act swiftly to investigate and resolve the matter.

11 Third-Party Links

11.1  The bt111 Platform may contain references to third-party services such as payment providers (bKash, Nagad, Rocket) and game content studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi). Where such third-party services are accessed through the Platform, those parties operate their own privacy policies that are independent of bt111's Privacy Policy.

11.2  bt111 is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party service provider before submitting personal data to them. bt111's Privacy Policy applies solely to data collected and processed by bt111 in connection with the bt111 Platform.

12 Amendments to This Privacy Policy

12.1  bt111 reserves the right to amend this Privacy Policy at any time. When we make material changes to this policy, we will notify registered players by posting a prominent notice on the bt111 Platform and, where practicable, by sending a notification to the mobile number or email address associated with your account.

12.2  The "Last Updated" date at the top of this Privacy Policy will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how bt111 protects your personal data.

12.3  Your continued use of the bt111 Platform following notification of a material change to this Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any amendment, you should cease using the Platform and contact [email protected] to request account closure.

13 Contact Us

13.1  If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by bt111, please contact us using the details below. bt111 aims to respond to all privacy-related enquiries within 5 business days.

13.2  If you are not satisfied with bt111's response to your privacy enquiry, you have the right to escalate your complaint to the relevant data protection authority or consumer protection body in your jurisdiction.