vc111 Privacy Policy – How We Handle Your Data

Introduction and Scope

This Privacy Policy ("Policy") is issued by vc111 ("Platform", "we", "us", "our") and applies to all personal data collected from users ("you", "Player", "Account Holder") who access or use the vc111 online gaming platform at vc111.pro, including any associated mobile interface, customer support channels, or promotional communications. By creating an account or using the Platform, you consent to the data practices described in this Policy.

This Policy is intended to give you a clear and honest account of how vc111 handles personal information. We do not use unnecessarily complex legal language — if a section is unclear, please contact our support team and we will explain it to you in plain terms. We review and update this Policy periodically to ensure it reflects our current data practices and any applicable regulatory developments.

Personal Data We Collect

vc111 collects personal data through several channels: account registration, transaction processing, gameplay activity, customer support interactions, and automated technical systems. The table below summarises the categories of data we collect, the source of each category, and the primary purpose for which it is used:

We collect only the data that is necessary for the stated purposes. We do not collect sensitive data categories such as biometric data, health information, or political opinions. Where we collect data under a consent basis, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

How We Use Your Personal Data

Personal data collected by vc111 is used strictly for the following purposes. We do not use your data for purposes incompatible with those listed below without first seeking your consent:

• Account creation and management: To register your account, verify your identity, maintain your profile, and process your login sessions securely.
• Financial transactions: To process deposits and withdrawals through bKash, Nagad, Rocket, Upay, and supported internet banking channels; to maintain accurate financial records; and to comply with applicable financial reporting obligations.
• Regulatory compliance: To satisfy our obligations under applicable anti-money laundering (AML) rules, know-your-customer (KYC) requirements, and any applicable laws of Bangladesh relating to online gaming and financial services.
• Security and fraud prevention: To monitor account activity for signs of fraud, money laundering, underage gambling, or other prohibited conduct; to investigate suspicious activity; and to protect the integrity of the Platform for all users.
• Customer support: To handle your queries, complaints, and requests; to maintain records of our communications with you for quality assurance and dispute resolution purposes.
• Responsible gaming: To monitor gameplay patterns that may indicate problem gambling; to apply deposit limits, time-outs, and self-exclusions as requested by the account holder; and to contact players whose activity triggers our responsible gaming thresholds.

Legal Basis for Processing

vc111 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and vc111, including account creation, transaction processing, and providing access to Platform services.
• Legal obligation: Processing necessary to comply with applicable AML regulations, KYC requirements, age verification obligations, and any other legal or regulatory duty to which vc111 is subject.
• Legitimate interests: Processing for the purposes of fraud prevention, platform security, responsible gaming monitoring, and business analytics, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for optional purposes such as sending you promotional communications about bonuses, new games, and seasonal offers. You may withdraw consent at any time by contacting support or updating your account preferences.

Payment Data and Mobile Wallet Security

vc111 does not store your full bKash, Nagad, or Rocket account credentials on our servers. When you initiate a deposit or withdrawal, your payment details are transmitted directly to the relevant payment processor using encrypted connections. vc111 retains only a tokenised or truncated reference to your payment account (for example, the last four digits of a mobile number) sufficient to match incoming and outgoing transactions to your account.

Transaction records — including the amount, timestamp, reference number, and payment method type — are retained for a minimum of five years in accordance with applicable financial record-keeping requirements. These records are used for dispute resolution, AML reporting, and audit purposes and are accessible only to authorised vc111 personnel and, where required by law, to relevant regulatory authorities.

Cookies and Tracking Technologies

vc111 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that allow the Platform to recognise your browser, maintain your session, and improve your experience. We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in while you navigate the site. These cookies cannot be disabled without breaking core Platform functionality.
• Performance cookies: Used to collect anonymised data about how players use the Platform, including which pages are visited most frequently and where errors occur. This data is used to improve Platform performance and user experience.
• Functional cookies: Used to remember your preferences and settings, such as your selected language, preferred payment method, and responsible gaming limits, so you do not have to re-enter them on each visit.
• Analytics cookies: Used to understand aggregate player behaviour and improve our promotional and product decisions. Analytics data is processed in anonymised or pseudonymised form and is not used to identify individual players.

You may control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform — in particular, disabling strictly necessary cookies will prevent you from remaining logged in during a session. vc111 does not use cookies to track your activity on third-party websites.

Data Sharing and Third Parties

vc111 does not sell, rent, or trade your personal data to third parties for marketing purposes. We share data only in the following circumstances, and only to the extent necessary for the stated purpose:

• Payment processors: We share necessary financial and identity data with bKash, Nagad, Rocket, Upay, and supported banking partners to facilitate deposits and withdrawals. These providers operate under their own privacy policies and are bound by contractual data protection obligations with vc111.
• Game providers and platform technology partners: Game providers such as Pragmatic Play, Evolution Gaming, and Spribe may receive anonymised session data to support game performance and fairness auditing. They do not receive your identity or financial data.
• Law enforcement and regulatory authorities: We will disclose personal data to competent authorities in Bangladesh or internationally where we are required to do so by law, court order, or regulatory direction. We will notify you of such disclosure where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of vc111's business, personal data held by vc111 may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer in advance.

Data Retention Periods

vc111 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and identity data: Retained for the duration of the account's active life plus a minimum of five years following permanent account closure, in compliance with AML and financial record-keeping requirements.
• Transaction records: Retained for a minimum of five years from the date of the transaction. Extended retention may apply where records are subject to an ongoing investigation or regulatory inquiry.
• Customer support communications: Retained for two years from the date of the last communication in each support thread, unless the subject matter of the communication relates to a dispute, in which case records are retained until the dispute is fully resolved plus two years.

When a retention period expires, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual. Anonymised or aggregated data derived from your account may be retained indefinitely for statistical and product improvement purposes, as it no longer constitutes personal data.

Your Data Rights

Subject to applicable law, you have the following rights in relation to your personal data held by vc111. To exercise any of these rights, contact our support team at [email protected] with your account username and a description of your request. We will respond within five business days:

• Right of access: You may request a copy of the personal data we hold about you, together with information about how it is processed and with whom it has been shared.
• Right to rectification: If any of the personal data we hold about you is inaccurate or incomplete, you may request that we correct or complete it. We will action your request within five business days.
• 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. Note that we may be required to retain certain data by law even after an erasure request.
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances, for example while a rectification request is being investigated.
• Right to object: You may object to the processing of your personal data where we rely on our legitimate interests as the legal basis, and where your particular situation gives you grounds to object. You may also object at any time to the processing of your data for direct marketing purposes.
• Right to data portability: Where processing is based on your consent or on a contract with you, and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format so you can transfer it to another service provider.

vc111 will not charge a fee for handling data rights requests submitted in good faith. However, where requests are manifestly unfounded or excessive (for example, repetitive requests for the same data), we reserve the right to charge a reasonable administrative fee or to refuse the request, with written reasons provided.

Data Security Measures

vc111 implements a layered approach to data security. Technical measures include 256-bit SSL/TLS encryption for all data transmitted between your device and our servers; encrypted storage of sensitive data at rest; access controls that restrict internal staff access to personal data on a need-to-know basis; regular security auditing and penetration testing of our Platform infrastructure; and intrusion detection systems that monitor for unauthorised access attempts in real time.

Organisational measures include mandatory data protection training for all staff who handle personal data; written confidentiality obligations for employees and contractors; a formal data breach response procedure that includes notification to affected users within 72 hours of discovery where required; and a dedicated data protection contact responsible for overseeing compliance with this Policy.

Children and Minors

vc111 is strictly an adult gaming platform. We do not knowingly collect personal data from any person under the age of 21. Registration requires confirmation that the user is aged 21 or above, and identity verification procedures are in place to enforce this requirement. If we discover that personal data has been collected from a person under the age of 21, that data will be immediately and permanently deleted, the associated account will be closed, and any funds in the account will be forfeited in accordance with our Terms & Conditions. If you believe that a minor has created an account on vc111, please contact our support team at [email protected] immediately.

Changes to This Privacy Policy

vc111 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform functionality. When we make material changes, we will notify registered account holders via their registered mobile number or via a prominent notice on the Platform at least 7 days before the change takes effect. The "Last updated" date at the top of this Policy will always reflect the most recent revision. We encourage you to review this Policy periodically. Your continued use of the Platform after any change to this Policy takes effect constitutes your acceptance of the revised Policy.

Contact and Data Queries

For any questions about this Privacy Policy, to exercise your data rights, or to report a concern about how your data is being handled, please contact the vc111 data support team. Our team is available 24 hours a day, 7 days a week via live chat on the Platform or by email. We aim to respond to all data-related queries within five business days.

Email: [email protected]