Privacy Policy

ct111 ("we", "us", "our", or "the Platform") is an English-language online betting and live casino information platform operated at https://ct111.cam. This Privacy Policy governs how ct111 collects, processes, stores, shares and protects personal data in connection with your use of the Platform.

This Privacy Policy applies to all users who visit, browse, register on or otherwise interact with the Platform, regardless of the device or location from which they access it. By continuing to use the Platform after reading this Policy, you acknowledge that you have understood its terms and consent to the data practices described herein.

ct111 is committed to handling personal data responsibly, transparently and in compliance with applicable data protection legislation. We do not sell personal data to third parties for their own marketing purposes, and we will never use your data in a manner inconsistent with this Policy without your prior consent.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

ct111 collects only the personal data that is necessary for operating the Platform, delivering services to Users, and meeting applicable legal obligations. The categories of data we may collect are set out in the table below:

We do not intentionally collect Special Category data (e.g., health, religion, political views) unless expressly required by law or responsible gambling obligations. Where such data is incidentally disclosed in a support communication, it will be handled with heightened care and not used for marketing or profiling purposes.

ct111 collects personal data through several means, all of which are described below. We aim to be transparent about every data collection touchpoint on the Platform:

• Account registration: When you create an Account, you voluntarily provide Identity Data and Contact Data, including your full name, email address, phone number and city of residence.
• KYC verification: To comply with age-verification and anti-money-laundering requirements, you may be required to submit a copy of a government-issued identity document. This data is processed securely and is not retained beyond the period required by law.
• Browsing and usage tracking: The Platform automatically collects Technical Data and Usage Data as you navigate. This includes your IP address, browser fingerprint, device type and session activity.
• Cookies and similar technologies: The Platform uses cookies, web beacons and local storage to remember your preferences, measure performance and detect fraudulent behaviour. See Section 8 for full details.
• Customer support interactions: When you contact the ct111 support team by email or live chat, the content of those communications is collected and stored to manage your enquiry and improve service quality.
• Payment transactions: When you initiate a deposit or withdrawal via the Operator's platform, basic transaction data — such as payment method type and amount in PKR — may be shared with ct111 for reconciliation and fraud screening purposes. Full payment instrument details (e.g., card numbers, Easypaisa or JazzCash wallet credentials) are handled exclusively by the Operator and its licensed payment processors.
• Third-party sources: In certain circumstances, we may receive data about you from third-party identity verification services, fraud-prevention databases or publicly available sources, where this is necessary to comply with legal obligations.

ct111 processes personal data only for the purposes for which it was collected, or purposes that are compatible with those original purposes. The specific uses of your personal data are set out below:

• Account management: Creating, maintaining and administering your registered Account, including credential management and account security.
• Identity and age verification: Confirming that you meet the minimum age requirement (18 years, or the higher minimum required by the Operator's licence jurisdiction) and that your identity is genuine, as part of KYC compliance.
• Service delivery: Providing access to sports odds, live casino content, betting guides and responsible gambling resources available on the Platform.
• Financial processing: Facilitating deposits and withdrawal requests in conjunction with the Operator and licensed payment processors. Payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are mentioned for contextual familiarity only; these providers handle their own data in accordance with their respective privacy policies.
• Fraud and security: Detecting, investigating and preventing fraudulent activity, money laundering, account takeovers and other prohibited conduct.
• Responsible gambling compliance: Managing self-exclusion requests, deposit and loss limits, session time controls and any other safer gambling measures you have activated.
• Platform improvement: Analysing aggregated usage data to understand how the Platform is used and to improve its content, performance and user experience.
• Legal compliance: Meeting obligations imposed by applicable law, regulatory bodies or court orders, including anti-money-laundering (AML) and counter-terrorist-financing (CTF) requirements.
• Marketing and promotions: Sending you relevant promotional communications about ct111 offers and operator promotions, but only where you have given explicit consent. You may opt out at any time.

Where applicable data protection law requires a legal basis for processing personal data, ct111 relies on one or more of the following grounds:

• Contractual necessity: Processing that is necessary for the performance of the contract between you and ct111 — for example, Account registration, KYC verification and deposit processing.
• Legal obligation: Processing required to comply with applicable law — including AML/CTF obligations, age verification requirements and data retention mandates.
• Legitimate interests: Processing carried out for purposes of fraud prevention, platform security, service improvement and responsible gambling enforcement, where those interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes such as marketing communications and the use of non-essential cookies, where you have given a clear and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Where consent is the legal basis, you will be asked to provide it through a clear opt-in mechanism. We will not bundle consent requests with other terms in a way that makes consent non-voluntary.

ct111 does not sell personal data to third parties. We may, however, share your data with carefully selected third parties in the following circumstances:

• The Operator: Your Account data, KYC results and transaction information are shared with the licensed Operator to enable gameplay, payment processing and regulatory compliance. The Operator is contractually bound to handle this data in accordance with its own privacy policy and applicable gaming regulations.
• KYC and identity verification providers: Specialist third-party services used to verify your identity and age. These providers process your data as Data Processors under contract with ct111 and may not use your data for their own independent purposes.
• Payment processors: Where a payment transaction is initiated, relevant transactional data is shared with licensed payment service providers. ct111 does not retain full payment instrument details.
• Analytics and technology providers: Providers of hosting, analytics, security and content delivery services that process usage data on our behalf as Data Processors.
• Legal and regulatory authorities: Where required by law, court order or regulatory directive, ct111 may disclose personal data to competent authorities, including law enforcement and financial intelligence units.
• Business transfers: In the event of a merger, acquisition or asset sale, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

ct111 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies may be set when you visit ct111:

• Strictly necessary cookies: Essential for the Platform to function. They include session management, security tokens and load-balancing cookies. These cannot be disabled without impairing core functionality.
• Performance and analytics cookies: Used to understand how visitors interact with the Platform — including which pages are visited most, how long sessions last and where errors occur. Data is aggregated and anonymised where possible.
• Functionality cookies: Remember your preferences such as language settings, display options and login state, so you do not have to re-enter them on each visit.
• Targeting and marketing cookies: Used only where you have provided consent. These cookies track your browsing activity to deliver relevant promotional content and measure the effectiveness of marketing campaigns.

You can manage your cookie preferences through the cookie consent banner displayed on your first visit, or through your browser settings. Disabling certain cookie categories may affect your experience on the Platform. Note that blocking strictly necessary cookies may prevent you from accessing Account features entirely.

ct111 does not use cookies to collect data from users it knows to be under 18 years of age. If we become aware that a user under the minimum eligible age has provided data, that data will be deleted promptly.

ct111 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:

• Account data: Retained for the duration of your Account plus a post-closure retention period as required by AML, gaming licensing and tax regulations (typically five to seven years following Account closure).
• KYC documents: Retained in accordance with AML obligations for a minimum period of five years from the date of verification or Account closure, whichever is later.
• Transaction data: Retained for the period required by applicable financial regulation, typically five years from the date of transaction.
• Support communications: Retained for up to three years following resolution of the query, or longer if the matter relates to ongoing legal proceedings.
• Analytics and usage data: Typically retained in anonymised or aggregated form indefinitely for platform improvement purposes. Identifiable usage data is deleted or anonymised after 24 months.
• Marketing consent records: Retained for three years from the date of last consent or opt-out, to demonstrate compliance with consent obligations.

When the retention period expires, data is securely deleted or anonymised in a manner that prevents reconstruction of your identity. You may request earlier deletion of your data in accordance with the rights described in Section 10, subject to overriding legal retention obligations.

Subject to applicable data protection law and the terms of any overriding legal obligation, you have the following rights in relation to your personal data held by ct111:

• Right of access: You may request a copy of the personal data ct111 holds about you, together with information about how it is used and with whom it is shared.
• Right to rectification: If any personal data held about you is inaccurate or incomplete, you may request that it be corrected or completed without undue delay.
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where consent has been withdrawn, or where processing is otherwise unlawful. This right is subject to legal retention obligations.
• Right to restriction of processing: You may request that ct111 restrict the processing of your data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to data portability: Where processing is based on consent or contractual necessity 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. ct111 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right not to be subject to solely automated decisions: You have the right to request human review of any decision made about you solely by automated means that produces a significant legal or similar effect.

To exercise any of the above rights, please contact the ct111 support team at the email address set out in Section 14. We will respond to all rights requests within 30 days of receipt. Complex or multiple requests may require up to 90 days, in which case we will inform you of the extension and the reason for it.

ct111 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest using industry-standard algorithms;
• Access controls that restrict internal access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Secure data deletion procedures applied at end-of-retention;
• Staff training on data protection and information security best practices.

While ct111 takes all reasonable steps to safeguard your data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, ct111 will notify affected users without undue delay and will report the breach to the relevant supervisory authority where required by law.

You also have a role to play in keeping your Account secure. You are responsible for maintaining the confidentiality of your login credentials and for notifying ct111 promptly if you suspect any unauthorised access to your Account.

The Platform is intended exclusively for adults aged 18 years or older, or the higher minimum age required by the Operator's licence jurisdiction. ct111 does not knowingly collect, process or retain personal data from individuals under the applicable minimum age.

Age verification is enforced through the KYC process. If ct111 becomes aware — or has reasonable grounds to suspect — that a user is under the minimum age, the Account will be suspended immediately, access to the Platform will be revoked and any personal data held will be deleted as soon as practicable, subject to overriding legal obligations.

If you believe that a minor has registered an Account or provided personal data to ct111 without appropriate consent, please contact the support team immediately using the contact details in Section 14. We will investigate and take appropriate action without delay.

ct111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, data processing practices or Platform functionality. When material changes are made, the "Last updated" date at the top of this page will be revised accordingly.

Where a change significantly affects how your personal data is processed, ct111 will provide advance notice through an in-platform notification or by email to your registered address, where practicable. For changes that require your fresh consent — such as a new use of your data for marketing — we will request that consent explicitly before proceeding.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes acceptance of the revised terms. We encourage you to review this Policy periodically so that you remain informed about how your data is being handled. Previous versions of this Policy may be made available upon written request to the support team.

If you have any questions, concerns or complaints regarding this Privacy Policy or the way ct111 handles your personal data, please contact our support team using the details below. All privacy-related enquiries will be handled with care and responded to within 30 days.

When submitting a privacy rights request, please include your full name, registered email address and a clear description of your request. We may ask you to verify your identity before processing your request. For responsible gambling related matters, please visit our Responsible Gambling page or indicate this clearly in your message so it can be prioritised.