Introduction
xp111 ("we", "us", "our" or "the Platform") is committed to protecting the privacy and personal data of all users who access https://xp111.cam. This Privacy Policy ("Policy") sets out, in accordance with applicable data-protection principles, how xp111 collects, uses, stores, shares and safeguards personal data provided by or collected from users ("you", "your", "User") of the Platform.
This Policy applies to all personal data processed by xp111 in connection with your use of the Platform. It should be read alongside our Terms and Conditions, which govern your use of the Platform as a whole, and our Responsible Gambling policy, which addresses our commitments to safe and informed gaming.
By using the xp111 Platform, you confirm that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform.
Definitions
For the purposes of this Privacy Policy, the following terms have the meanings set out below:
- "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers and browsing behaviour.
- "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure or destruction.
- "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, the Data Controller is xp111.
- "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement.
- "Cookies" — small text files placed on your device by the Platform to store preferences and usage information.
- "Platform" — the xp111 website located at https://xp111.cam and all associated sub-pages.
- "User" — any individual who accesses or uses the Platform.
- "User Rights" — the rights granted to data subjects under applicable data-protection law, as further described in Section 10.
Personal Data We Collect
xp111 is an informational platform and does not require user registration or account creation to access content. The personal data we collect is therefore limited. We may collect the following categories of data:
3.1 Data You Provide Directly
If you contact us via our support email address ([email protected]) or submit a feedback enquiry through any contact mechanism made available on the Platform, we may collect:
- Your name (if provided);
- Your email address;
- The content of your message or enquiry.
3.2 Data Collected Automatically
When you access or use the Platform, we and our technology service providers may automatically collect certain technical and usage data, including:
| Category | Examples | Purpose |
|---|---|---|
| Device Information | Browser type and version, operating system, device type (mobile/desktop), screen resolution | Platform optimisation and compatibility |
| Connection Information | IP address, approximate geographic location (city/region level), internet service provider | Security, fraud prevention, analytics |
| Usage Data | Pages visited, time spent on pages, referral source, links clicked, scroll depth | Content improvement, editorial decisions |
| Cookie Data | Session identifiers, preference settings, analytics identifiers | Platform functionality, analytics (see Section 6) |
3.3 Data We Do Not Collect
xp111 does not collect, process or store the following categories of data:
- Payment card details, bank account information or any financial transaction data (xp111 is not a gambling platform and does not process payments);
- Government-issued identity documents such as CNIC or passport numbers;
- Biometric data or health data;
- Data from minors — see Section 11 for our approach to children's privacy.
How We Use Your Personal Data
xp111 processes personal data for the following purposes only. We do not use personal data for any purpose incompatible with those stated below.
- Platform operation and delivery: To ensure the Platform loads correctly, functions as intended, and serves the appropriate content to your device and location;
- Correspondence and enquiry handling: To read, process and respond to messages you send to our support address. We retain correspondence for a reasonable period to resolve any follow-up queries;
- Analytics and content improvement: To understand how users navigate the Platform so we can improve editorial content, fix technical issues and prioritise features that serve Pakistani users better;
- Security and fraud prevention: To detect, investigate and prevent malicious activity, including automated scraping, denial-of-service attacks and unauthorised access attempts;
- Legal compliance: To comply with applicable laws and regulations, respond to lawful requests from competent authorities, and enforce our Terms and Conditions.
Legal Basis for Processing
xp111 relies on the following legal grounds for processing personal data, consistent with internationally recognised data-protection principles:
- Legitimate interests: For the collection of technical and usage data necessary to operate, maintain and improve the Platform. Our legitimate interest in providing a functional and secure informational platform does not override your fundamental rights and freedoms;
- Consent: For any processing activities beyond what is strictly necessary to operate the Platform, such as optional analytics or feedback mechanisms, where we have obtained your prior, informed and freely given consent;
- Contractual necessity: For processing your enquiry or feedback where you have initiated contact with us, to the extent necessary to respond;
- Legal obligation: Where processing is required to comply with a legal obligation applicable to xp111.
Where we rely on consent as a legal basis, you may withdraw that consent at any time by contacting us at [email protected]. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal.
Cookies & Similar Tracking Technologies
xp111 uses cookies and similar technologies to ensure the Platform functions correctly and to gather aggregated analytics data. No personally identifiable information is stored within cookies except as set out below.
6.1 Types of Cookies We Use
- Strictly Necessary Cookies: These are essential for the Platform to function and cannot be disabled. They are set in response to actions you take, such as setting privacy preferences. They do not store personally identifiable information;
- Analytics Cookies: These cookies help us understand how users interact with the Platform by collecting aggregated usage statistics. We use this data to improve the editorial quality and technical performance of the Platform;
- Preference Cookies: These cookies remember your choices (such as language or content preferences) to personalise your experience on subsequent visits.
6.2 Managing Cookies
Most web browsers allow you to control and delete cookies through their settings. You can configure your browser to refuse all cookies, to notify you when a cookie is being set, or to accept cookies only from specific sites. Please note that disabling certain cookies may affect Platform functionality.
Sharing Personal Data with Third Parties
xp111 does not sell, rent, licence or otherwise trade personal data with third parties. We may share personal data in limited circumstances, as described below.
7.1 Service Providers (Data Processors)
We engage reputable third-party service providers to assist with the operation of the Platform, including web hosting, content delivery networks and analytics services. These providers act as Data Processors on our behalf and are permitted to process personal data only in accordance with our documented instructions. They are contractually prohibited from using your data for their own commercial purposes.
7.2 Legal Disclosures
We may disclose personal data to competent authorities, courts or other public bodies where we are legally required to do so, where we believe disclosure is necessary to protect our legal rights, or where disclosure is required to prevent or investigate illegal activity.
7.3 Payment References — No Data Sharing
Although xp111 references Pakistani payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah in its editorial content for contextual purposes, we share absolutely no user data with any of these providers. These references are purely informational. xp111 does not have a commercial or data-sharing relationship with any of these payment providers.
7.4 Business Transfers
In the event of a merger, acquisition, restructuring or sale of all or substantially all of xp111's assets, personal data held by xp111 may be transferred to the acquiring entity, subject to the same data-protection commitments set out in this Policy. We will notify users of any such transfer in accordance with applicable law.
Data Retention
xp111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or to comply with applicable legal, regulatory or reporting obligations.
- Enquiry and correspondence data: Retained for a period of twelve (12) months from the date of last correspondence, after which it is securely deleted unless a legal obligation requires longer retention;
- Analytics data: Retained in aggregated or anonymised form for up to twenty-four (24) months for Platform improvement purposes. Anonymised data may be retained indefinitely as it cannot be used to identify individuals;
- Technical log data (IP addresses, server logs): Retained for a period of ninety (90) days for security and diagnostic purposes, then deleted.
When data is no longer required, it is securely deleted or anonymised in accordance with our data-disposal procedures.
Data Security
xp111 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include, but are not limited to:
- HTTPS encryption for all data transmitted between your browser and the Platform;
- Access controls limiting who within xp111 can access personal data, on a need-to-know basis;
- Regular security assessments of the Platform and its supporting infrastructure;
- Contractual obligations requiring third-party service providers to maintain equivalent security standards.
No method of electronic transmission or storage is entirely secure. While we take our security obligations seriously, we cannot guarantee the absolute security of data transmitted over the internet. Users transmit data to xp111 at their own risk. If you believe your personal data may have been compromised, please contact us immediately at [email protected].
Your Rights as a Data Subject
Subject to applicable data-protection law, you have the following rights in respect of your personal data held by xp111. To exercise any of these rights, please contact us at [email protected] with a clear description of your request.
Right of Access
You may request a copy of the personal data xp111 holds about you, along with information about how and why it is being processed.
Right to Rectification
If you believe any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it.
Right to Erasure
You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent.
Right to Restrict Processing
You may request that we restrict the processing of your personal data in certain circumstances, such as while a dispute about accuracy is resolved.
Right to Data Portability
Where we process your personal data by automated means on the basis of consent or contract, you may request a copy in a structured, machine-readable format.
Right to Object
You have the right to object to processing of your personal data where we rely on legitimate interests as our legal basis. We will cease processing unless we demonstrate compelling grounds that override your interests.
Minors
The xp111 Platform is strictly intended for users who are 18 years of age or older (or such higher minimum age as may be required by the applicable operator or licence jurisdiction). xp111 does not knowingly collect, process or store personal data from individuals under the age of 18.
If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data from our systems. If you are a parent or guardian and believe a minor in your care has provided personal data to xp111, please contact us immediately at [email protected].
We strongly encourage parents and guardians to use parental-control and content-filtering tools to prevent minors from accessing online gambling-related content, including informational platforms such as xp111.
Pakistan-Specific Privacy Context
xp111 is an English-language platform specifically designed for users in Pakistan, including users in major cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We acknowledge that Pakistani data-protection law is an evolving area. While Pakistan's Personal Data Protection Bill has been under development, users should be aware that the legal framework governing data privacy in Pakistan continues to develop.
Regardless of the specific legal framework applicable at any given time, xp111 commits to applying internationally recognised data-protection principles — including purpose limitation, data minimisation, storage limitation and security — as a baseline standard for all personal data processing.
As noted throughout this Policy, xp111 references payment provider names familiar to Pakistani users (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) in an editorial and contextual capacity only. No personal financial data is shared with, transmitted to, or received from any of these providers in connection with your use of the Platform.
Policy Amendments
xp111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our practices, legal obligations or the services we provide. Any material changes to this Policy will be published on this page with an updated "Last updated" date at the top of the document.
We encourage all users to review this Policy periodically to remain informed about how we protect your personal data. Where a change is material — for example, where we begin processing a new category of personal data or sharing data with new categories of third parties — we will take reasonable steps to provide enhanced notice, such as a prominent notification on the Platform's homepage.
Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes and your agreement to be bound by the updated Policy.
Contact Us — Privacy Enquiries
If you have any questions, concerns or requests relating to this Privacy Policy or to the personal data xp111 holds about you, please contact our team using the details below. We are committed to handling all privacy enquiries diligently and in good faith.
Platform: xp111 — https://xp111.cam
Privacy enquiries email: [email protected]
Subject line recommended: "Privacy Enquiry" or "Data Rights Request"
Language of correspondence: English
Response channel: Digital only — no Pakistan office address or local phone number is maintained.
We aim to respond to all privacy-related enquiries within thirty (30) days of receipt. Complex requests may require additional time, in which case we will acknowledge your enquiry and provide an estimated response timeframe.