net11 Privacy Policy — How We Protect Your Personal Data

1 Introduction

Welcome to the net11 Privacy Policy. net11 ("we", "us", "our") operates the online betting and gaming platform accessible at net11.io (the "Platform"), which is designed and optimised for players based in Bangladesh. We are committed to protecting the personal data of every user who registers an account, visits our website, or interacts with our services in any capacity.

This Privacy Policy describes in plain and transparent terms the categories of personal data we collect from you, the purposes for which that data is processed, the legal grounds on which processing is based, the circumstances in which data may be shared with third parties, and the rights you are entitled to exercise in relation to your personal information.

This Policy forms part of the net11 User Agreement alongside the Terms & Conditions and the Responsible Gaming Policy. By creating a net11 account or continuing to use the Platform, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal information is net11, the operator of the net11.io Platform. As data controller, net11 determines the purposes for which your personal data is processed and the means by which that processing is carried out.

If you have any questions or concerns about how net11 handles your personal data, or if you wish to exercise any of the rights described in Section 10 of this Policy, you may contact our Data Protection team through any of the channels listed in Section 15 (Contact Us).

3 Data We Collect

net11 collects the following categories of personal data from users of the Platform:

3.1 Identity Data

Full legal name, date of birth, gender, nationality, and copies of identity documents such as a national identity card, passport, or birth certificate, collected as part of our Know Your Customer (KYC) verification process.

3.2 Contact Data

Email address, mobile phone number, and residential address including city, district, and postal code. For players in Bangladesh, this typically includes addresses in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar.

3.3 Account & Credentials Data

Username, encrypted password, account registration date, last login timestamp, preferred language setting, and any communication preferences you have configured within your net11 account dashboard.

3.4 Financial Data

Transaction history including deposit amounts, withdrawal requests, betting stakes, winnings, and bonus credits. Payment method identifiers such as bKash mobile wallet numbers, Nagad account references, Rocket account references, Upay references, and masked Visa or Mastercard numbers (we do not store full card numbers). All monetary values are recorded in Bangladeshi Taka (BDT, ৳).

3.5 Technical & Usage Data

IP address, device type, operating system, browser type and version, screen resolution, referring URL, pages visited within the Platform, session duration, click patterns, game history, bet slips, and in-play betting activity.

3.6 Communications Data

The content and metadata of any messages you send to net11 customer support via live chat or email, including timestamps, support ticket numbers, and the nature of any complaint or query raised.

3.7 Responsible Gaming Data

Any deposit limits, loss limits, session time limits, cooling-off periods, or self-exclusion requests you set through the Platform's responsible gaming tools, including the dates on which such restrictions were applied or modified.

4 How We Collect Data

net11 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or updating your account profile;
• Automated collection: Technical and usage data collected automatically via cookies, web beacons, server logs, and similar tracking technologies when you visit or interact with the Platform (see Section 9 — Cookies & Tracking);
• Third-party sources: Identity and address verification data received from KYC service providers; fraud-risk signals from payment processors; geolocation data from IP intelligence services used to enforce regional access controls;
• Game providers: Game session data, bet history, and RNG outcome records shared with net11 by our third-party game providers including Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, and Spribe for account reconciliation and dispute resolution purposes.

5 Purpose & Legal Basis for Processing

net11 processes your personal data only where a valid legal basis exists. The table below sets out the primary purposes of processing and the corresponding legal ground relied upon:

Where net11 relies on your consent as a legal basis (for example, to send you promotional communications about bonuses, new game launches, or seasonal offers), you have the right to withdraw that consent at any time by adjusting your communication preferences in your account dashboard or by contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6 Data Sharing

net11 does not sell, rent, or trade your personal data to third-party marketers or advertisers under any circumstances. Your data may be shared with the following categories of third parties solely to the extent necessary to operate the Platform and fulfil our legal obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — for the sole purpose of processing your deposit and withdrawal transactions;
• KYC and identity verification providers: Third-party services engaged to verify the authenticity of identity documents and confirm user eligibility in compliance with applicable age and anti-money laundering requirements;
• Game providers: Evolution Gaming, Pragmatic Play, Pragmatic Play Live, Ezugi, NetEnt, Microgaming, Spribe, and other licensed game studios — for bet settlement, dispute resolution, and game session reconciliation;
• IT and hosting providers: Cloud infrastructure and server hosting providers who store Platform data on secured servers under contractual data protection obligations;
• Fraud and risk management services: Specialist third-party fraud detection tools that analyse technical and behavioural data to identify suspicious activity on the Platform;
• Regulatory and law enforcement authorities: Where net11 is legally compelled to disclose information by court order, regulatory directive, or applicable law, including anti-money laundering reporting obligations.

All third parties to whom net11 discloses personal data are required to process that data solely for the specified purpose, to maintain appropriate technical and organisational security measures, and to comply with applicable data protection obligations. net11 does not permit third-party service providers to use your data for their own commercial purposes.

7 International Data Transfers

net11 operates as an internationally licensed offshore platform. As a result, your personal data may be transferred to, stored in, or processed in countries outside Bangladesh, including jurisdictions where data protection laws may differ from those in force in Bangladesh.

Where such international transfers take place, net11 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses in agreements with third-party processors that require them to maintain data protection standards equivalent to those applied by net11. By using the Platform, you acknowledge and consent to such transfers where they are necessary for the purposes described in this Privacy Policy.

8 Data Retention

net11 retains your 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 and identity data: Retained for the duration of your active account plus a minimum of 5 years after account closure, to satisfy anti-money laundering record-keeping requirements;
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, in accordance with financial record-keeping obligations;
• KYC documents: Retained for a minimum of 5 years from the date of submission or the date of account closure, whichever is later;
• Communications data (support logs): Retained for 3 years from the date of the interaction;
• Technical and usage data: Aggregated and anonymised within 24 months; individual session logs retained for 12 months;
• Responsible gaming records: Retained for 5 years from the date of the relevant restriction or self-exclusion request, to ensure compliance with our duty of care obligations.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents reconstruction of the original information.

9 Cookies & Tracking Technologies

net11 uses cookies and similar tracking technologies to operate the Platform, remember your session, prevent fraud, and analyse usage patterns. A cookie is a small text file stored on your device by your browser when you visit a website. net11 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that keep you logged in, security tokens that prevent cross-site request forgery, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality;
• Analytics cookies: Used to collect aggregated, anonymised data about how users navigate the Platform — including which pages are visited most frequently, where users arrive from, and how long sessions last. This data helps net11 improve the Platform experience;
• Functional cookies: Remember your preferences such as language setting, preferred sports markets, and display options so that these settings persist across sessions;
• Security and fraud-prevention cookies: Used to detect suspicious login attempts, identify unusual betting patterns, and flag potential account takeover activity.

You may control cookie settings through your browser's privacy or settings menu. Disabling cookies other than strictly necessary ones may affect the performance of some Platform features. net11 does not use third-party advertising cookies or behavioural targeting cookies that track your activity across other websites.

10 Your Rights

Subject to applicable law, you have the following rights in relation to the personal data net11 holds about you:

• Right of access: You may request a copy of the personal data net11 holds about you, together with information about how it is processed;
• Right to rectification: You may request that inaccurate or incomplete personal data be corrected. You may also update certain account details directly from your net11 account dashboard;
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to net11's legal retention obligations;
• Right to restriction of processing: You may request that net11 restrict the processing of your data in certain circumstances, for example while a rectification request is being assessed;
• Right to data portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you may request that your data be provided to you in a structured, commonly used, machine-readable format;
• Right to object: You may object to processing based on legitimate interests, including profiling carried out for fraud prevention or responsible gaming monitoring purposes, unless net11 can demonstrate compelling legitimate grounds that override your interests;
• Right to withdraw consent: Where processing is based on your consent (e.g., promotional communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact net11 support via live chat in your account dashboard or by emailing [email protected]. net11 will respond to all data subject requests within 30 days of receipt. In complex cases, this period may be extended by a further 60 days, in which case net11 will notify you of the extension and the reason for it.

Please note that some rights may be limited or overridden by net11's legal obligations — for example, the right to erasure cannot be exercised in respect of financial transaction records that net11 is required to retain under anti-money laundering law.

11 Security Measures

net11 takes the security of your personal data seriously and has implemented a layered set of technical and organisational measures to protect against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption: All data transmitted between your device and the net11 Platform is encrypted using industry-standard Transport Layer Security protocols. This applies to account login, payment processing, and all API communications;
• Encrypted data storage: Sensitive personal data including identity documents, financial records, and password hashes are stored in encrypted form on secured servers with restricted access controls;
• Access control and authentication: Internal access to personal data is limited to net11 personnel who require it for legitimate business purposes. All internal access is logged and subject to audit;
• Intrusion detection systems: Net11's infrastructure is monitored continuously for anomalous activity, attempted breaches, and denial-of-service attacks;
• Regular security assessments: net11 conducts periodic security reviews of its infrastructure and engages third-party specialists to perform penetration testing and vulnerability assessments;
• Incident response: In the event of a confirmed personal data breach that poses a risk to affected users, net11 will notify affected account holders without undue delay and will take immediate remedial action.

While net11 employs industry-standard security practices, no online platform can guarantee absolute security against all possible threats. You are responsible for keeping your account login credentials confidential and for notifying net11 immediately if you suspect unauthorised access to your account.

12 Children's Privacy

net11 enforces a strict minimum age requirement of 21 years for all account registrations. Age verification is carried out as part of the KYC process, and accounts found to belong to individuals below the minimum age will be closed immediately, with all balances forfeited in accordance with the net11 Terms & Conditions.

If you are a parent or guardian and you believe that a person under the age of 21 has registered a net11 account or accessed the Platform using your details or their own, please contact net11 support immediately via live chat or at [email protected]. net11 will investigate and, if confirmed, close the account and delete any personal data belonging to the underage individual as soon as reasonably practicable.

13 Third-Party Links

The net11 Platform may contain references to or integrations with third-party game providers whose game interfaces are embedded within the Platform. While net11 takes care to work only with reputable, licensed providers, net11 is not responsible for the privacy practices of third-party game providers or their underlying software platforms.

Each game provider operates under its own privacy policy and data processing arrangements. net11 recommends that you review the privacy policies of game providers whose content you access through the Platform if you have concerns about how they handle data generated during gameplay sessions.

This Privacy Policy applies solely to data collected and processed by net11 directly through the net11.io Platform. It does not extend to any third-party website, service, or application that may be referenced on the Platform.

14 Policy Updates

net11 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or changes to the Platform's features and services. When material changes are made, net11 will notify registered users by posting a notice on the Platform and, where appropriate, by sending a notification to the email address registered on your account.

The effective date at the top of this Privacy Policy will be updated each time a new version is published. We encourage you to review this Policy periodically to stay informed about how net11 protects your personal data. Your continued use of the Platform following the publication of any revised Policy constitutes your acceptance of the changes.

If any revision to this Privacy Policy materially reduces your rights or significantly expands the scope of data processing in a way that requires fresh consent, net11 will seek your explicit consent before the revised terms take effect in relation to your data.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way net11 processes your personal data, please reach out to the net11 Data Protection team through any of the following channels:

• Live Chat: Available 24/7 directly from your net11 account dashboard — the fastest way to reach us for urgent data or account queries;
• Email: [email protected] — for formal data subject access requests or written privacy complaints;
• Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (UTC+6).

net11 aims to acknowledge all privacy-related written enquiries within 24 hours and to provide a substantive response within 30 calendar days. Where a request is complex or where net11 receives a high volume of requests simultaneously, the response period may be extended to 90 days in total, with notification to the requesting user.