cb111 Privacy Policy

Introduction

cb111 ("cb111", "we", "us", "our") is committed to protecting and respecting the privacy of every individual who interacts with our platform. This Privacy Policy ("Policy") sets out in full the basis on which any personal data we collect from you, or that you provide to us, will be processed by cb111. Please read this Policy carefully to understand our approach to your personal data and how we will treat it.

This Policy applies to all users of the cb111 website at cb111.io, the cb111 mobile-optimised platform, and any associated services, promotions, or communications operated under the cb111 brand. It applies to players registered in Bangladesh and all other markets where cb111 provides services.

This Policy should be read in conjunction with cb111's Terms & Conditions and, where applicable, any specific game or promotion terms. In the event of any conflict between this Policy and those documents on matters of data privacy, this Policy shall prevail.

Data We Collect

cb111 collects and processes the following categories of personal data:

2.1 Registration Data

When you create a cb111 account we collect your full legal name, date of birth, residential address, email address, and mobile phone number. This information is required to establish your account, verify your identity, and comply with our Know Your Customer (KYC) obligations.

2.2 Identity Verification Documents

To comply with anti-money laundering (AML) regulations and to protect the integrity of the platform, cb111 may request copies of government-issued identity documents. Acceptable documents include a valid National Identity Card (NID), passport, or driver's licence. We may also request proof of address in the form of a recent utility bill or bank statement, and proof of payment method ownership.

2.3 Financial & Transaction Data

cb111 records details of all financial transactions conducted through your account, including deposits, withdrawals, wagers, bonuses claimed, and refunds issued. This includes the payment method used (e.g., bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank), transaction reference numbers, amounts in BDT, and timestamps. cb111 does not store full payment account credentials — these are handled directly by the relevant payment providers using their own security infrastructure.

2.4 Usage & Activity Data

cb111 automatically collects data about how you use the platform, including games played, betting history, session durations, login timestamps, pages visited, features accessed, and in-platform communications. This data is used to operate the platform, detect fraud, personalise your experience, and improve our services.

2.5 Device & Technical Data

When you access cb111, we automatically collect technical data including your IP address, browser type and version, operating system, device type (desktop, mobile, tablet), screen resolution, referring URL, and approximate geographic location derived from your IP address. This data is used for security monitoring, fraud prevention, and platform analytics.

2.6 Communications Data

If you contact cb111 support via live chat, email, or any other channel, we record and retain those communications together with any attachments or screenshots provided. This enables us to investigate and resolve your enquiry and maintain a record of our correspondence with you.

2.7 Summary Table of Data Categories

How We Use Your Data

cb111 uses the personal data we collect for the following purposes:

• Account management: To create, maintain, and administer your cb111 account, process deposits and withdrawals, and ensure the correct operation of all platform features available to you.
• Identity verification: To verify your age, identity, and payment method ownership in compliance with our KYC obligations and to prevent underage gambling, fraud, and money laundering.
• Transaction processing: To process your deposits and withdrawals via bKash, Nagad, Rocket, Upay, and bank transfer, and to maintain accurate financial records of all transactions on your account.
• Platform security: To detect, investigate, and prevent fraudulent activity, multiple account abuse, bonus abuse, money laundering, and any other conduct that violates our Terms & Conditions.
• Legal compliance: To meet our obligations under applicable anti-money laundering, counter-terrorism financing, and data protection laws, including responding to lawful requests from law enforcement authorities.
• Customer support: To respond to your enquiries, resolve complaints, and provide assistance via live chat and email support.
• Responsible gaming: To monitor your gaming activity for signs of problem gambling behaviour and to action responsible gaming requests such as deposit limits, cooling-off periods, and self-exclusion.
• Marketing communications: To send you promotional offers, bonus notifications, and news about cb111 — only where you have given explicit consent and have not subsequently opted out.
• Platform improvement: To analyse aggregate usage data, identify technical issues, test new features, and continuously improve the cb111 platform experience.
• Legal disputes: To establish, exercise, or defend legal claims arising from your use of the cb111 platform.

Legal Basis for Processing

cb111 processes your personal data on the following legal bases:

4.1 Contract Performance

Processing of your registration data, transaction data, and account activity data is necessary for cb111 to perform the contract it has entered into with you (the Terms & Conditions) — specifically, to operate your account, process payments, and deliver the betting and gaming services you have requested.

4.2 Legal Obligation

Processing of identity verification documents and certain transaction records is required to enable cb111 to comply with its legal obligations under applicable anti-money laundering laws, counter-terrorism financing regulations, and any lawful directions issued by competent authorities.

4.3 Legitimate Interests

cb111 processes device and technical data, usage data, and communications data on the basis of its legitimate interests in operating a secure, fair, and commercially viable gaming platform. These interests include fraud prevention, platform security, dispute resolution, and service improvement. cb111 has assessed that these legitimate interests are not overridden by your privacy rights in relation to this category of data.

4.4 Consent

Where cb111 processes your personal data for marketing communications or for any purpose not covered by the bases above, we do so on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing & Disclosure

cb111 does not sell your personal data. We share personal data only in the following limited circumstances:

5.1 Payment Service Providers

To process your deposits and withdrawals, cb111 shares necessary transaction data with the payment service providers you have selected, including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and BRAC Bank. These providers receive only the data required to execute the transaction and are bound by their own data protection obligations.

5.2 KYC & Fraud Prevention Providers

cb111 may engage specialist third-party services to assist with identity verification, age verification, and fraud detection. Where such services are used, your personal data is shared under strict data processing agreements that prohibit the provider from using your data for any purpose other than the contracted service.

5.3 Game Content Providers

Game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Ezugi, and Spribe may receive anonymised session tokens or player identifiers necessary to deliver their games through the cb111 platform. These providers do not receive your full personal profile and are not permitted to use any data shared for their own marketing or profiling purposes.

5.4 Legal & Regulatory Authorities

cb111 will disclose personal data to law enforcement agencies, regulatory bodies, courts, or other competent authorities where required to do so by law or in response to a valid legal order. cb111 will, where legally permitted, notify affected users of such disclosure requests.

5.5 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or part of cb111's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and any material change to the processing of your data that results from it.

Data Retention

cb111 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 retention periods apply:

At the end of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. Where anonymised data is retained for statistical or analytical purposes, it is no longer considered personal data and is not subject to this Policy.

Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognise your device on subsequent visits and to store information about your preferences or actions. cb111 uses cookies and similar technologies (including local storage and session storage) to operate the platform and understand how it is used.

7.2 Types of Cookies Used by cb111

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in, security tokens that protect against cross-site request forgery, and cookies that remember your language and display preferences. These cannot be disabled without breaking core platform functionality.
• Analytical cookies: Used to understand how users navigate the cb111 platform in aggregate. Data collected is anonymised and used only for internal reporting and platform improvement. No individual user profile is built from analytical cookie data.
• Responsible gaming cookies: Store your responsible gaming settings (such as session time limits and reality-check intervals) locally on your device so that these preferences are respected across sessions without requiring a server lookup each time.

7.3 Cookies We Do Not Use

cb111 does not deploy advertising cookies, behavioural tracking cookies, or any cookie that tracks your activity across third-party websites. We do not use fingerprinting techniques or cross-device tracking for advertising purposes.

7.4 Managing Cookies

You may control and delete cookies through your browser settings. Most modern browsers allow you to refuse all cookies, accept only certain types, or delete existing cookies. Note that disabling essential cookies will impair your ability to use the cb111 platform — in particular, you will not be able to remain logged in or access account features. Disabling analytical cookies has no effect on core platform functionality.

International Data Transfers

cb111 is an internationally operated platform. Personal data collected from users in Bangladesh may be stored and processed on servers located outside Bangladesh, including in jurisdictions that may not provide the same level of data protection as your country of residence. Where such international transfers occur, cb111 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that described in this Policy.

Safeguards used for international transfers include standard contractual clauses incorporated into agreements with data processors, binding corporate rules where applicable, and transfers to jurisdictions that have been assessed to provide adequate data protection standards. By registering a cb111 account and accepting these terms, you acknowledge and consent to the transfer of your personal data on this basis.

Your Data Rights

Subject to applicable law, you have the following rights in relation to your personal data held by cb111:

• Right of access: You may request a copy of all personal data cb111 holds about you, together with information about how it is being processed. We will provide this within 30 days of a verified request.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you. Many fields can be updated directly through your account settings; others require a support request.
• 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, where you have withdrawn consent, or where processing is unlawful. This right is subject to cb111's legal obligation to retain certain data categories as outlined in Section 6.
• Right to restriction: You may request that cb111 restricts processing of your personal data while a dispute about accuracy or lawfulness is being resolved.
• Right to data portability: You may request a copy of your personal data in a structured, machine-readable format for the purposes of transferring it to another service provider where technically feasible.
• Right to object: You may object to processing of your personal data based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, cb111 will cease processing immediately.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please contact cb111's data team at [email protected] with the subject line "Data Subject Request" and a clear description of your request. We may request proof of identity before processing your request to protect against unauthorised data access. We aim to respond to all valid requests within 30 calendar days.

Children's Privacy

cb111 is strictly an adult platform. No individual under the age of 21 years is permitted to register an account, access the platform, or submit any personal data to cb111. cb111 does not knowingly collect personal data from individuals under the age of 21.

If cb111 discovers or reasonably suspects that personal data has been submitted by or on behalf of an individual under 21, the associated account will be immediately suspended, all data relating to that account will be securely deleted, and any deposits associated with the account will be subject to review in accordance with applicable responsible gaming procedures.

If you believe that a minor in your household has submitted personal data to cb111, please contact our support team immediately so that we can take prompt action. cb111 strongly encourages parents and guardians to make use of parental control software to prevent minors from accessing online gambling platforms.

Security Measures

cb111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Key measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the cb111 platform
• Encryption at rest for all personal data stored on cb111 servers
• Multi-factor authentication required for all staff access to systems holding personal data
• Role-based access controls limiting staff access to personal data to those with a documented business need
• Regular security audits and penetration testing conducted by independent third-party security specialists
• Intrusion detection systems monitoring for anomalous access patterns and potential data breaches in real time
• Staff training on data protection obligations and secure data handling practices, repeated annually
• Incident response plan ensuring that any confirmed data breach is investigated, contained, and notified to affected users and relevant authorities within the timeframes required by applicable law

Notwithstanding these measures, no online platform can guarantee absolute security. You are responsible for keeping your cb111 login credentials confidential and for ensuring that your device is adequately secured. If you suspect that your account has been compromised, contact our support team immediately via live chat or email.

Third-Party Links

The cb111 platform does not contain links to third-party websites for commercial or advertising purposes. Any third-party content delivered through the platform — such as games provided by Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Ezugi, or Spribe — is delivered within the cb111 environment under contractual data protection obligations and is not subject to separate third-party privacy policies in the context of your use of cb111.

cb111 is not responsible for the privacy practices of any external website or service that you choose to access independently outside of the cb111 platform. We encourage you to review the privacy policies of any third-party service you use in connection with your online activity.

Policy Updates

cb111 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 features. When material changes are made, cb111 will notify registered users by email or by a prominent notice on the cb111 platform prior to the change taking effect.

The date of the most recent revision is displayed at the top of this Policy. Continued use of the cb111 platform following notification of a material change constitutes your acceptance of the revised Policy. If you do not agree to any revised version of this Policy, you must discontinue use of the cb111 platform and close your account by contacting our support team.

Minor updates such as clarifications of existing language, corrections of typographical errors, or improvements to readability that do not alter the substance of this Policy may be made without prior notice. The version date at the top of the Policy will be updated accordingly.

Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which cb111 processes your personal data, please contact our data protection team using the details below. We are committed to resolving all privacy-related enquiries promptly and transparently.

• Email: [email protected] (subject line: "Privacy Policy Enquiry")
• Live Chat: Available 24 hours a day, 7 days a week via the cb111 platform
• Response time: We aim to acknowledge all privacy enquiries within 48 hours and provide a substantive response within 30 calendar days
• Support hours: 24 hours a day, Bangladesh Standard Time (UTC+6)

If you are not satisfied with cb111's response to your privacy enquiry, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction.