Privacy Policy — kt11 Data Commitment

1 Definitions

In this Privacy Policy, the following terms carry the meanings assigned below unless the context requires otherwise:

• "kt11", "we", "us", "our" — refers to the kt11 platform, its operators, and all affiliated entities responsible for the operation of the website at kt11.io.
• "Player", "you", "your" — any individual who accesses, browses, registers on, or otherwise interacts with the kt11 platform.
• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, including name, date of birth, address, mobile number, payment account details, and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "KYC" — Know Your Customer verification, being the identity, age, and address verification process required of all Players before withdrawal of funds.
• "BST" — Bangladesh Standard Time, UTC+6, the time zone applied to all platform operations and data retention schedules.
• "Third-Party Provider" — any external service provider engaged by kt11 to deliver services on the platform, including game studios, payment processors, and analytics providers.

2 Data We Collect

kt11 collects only the Personal Data that is necessary for the operation of the platform, the delivery of services to Players, and the fulfilment of legal and compliance obligations. The categories of data we collect are as follows:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (beyond identity photo for KYC), or health data, except where a Player voluntarily discloses health information in the context of a responsible gaming request.

3 How We Collect Data

kt11 collects Personal Data through the following channels:

• Direct Registration. When you create a kt11 Account, you provide Identity Data and Contact Data directly via the registration form.
• KYC Submission. When you submit identity documents for KYC verification, we collect Identity Data from those documents and retain verified copies as required.
• Deposits and Withdrawals. When you transact via bKash, Nagad, Rocket, or Upay, we receive transaction reference data from those payment providers confirming successful payment instructions.
• Automated Technologies. When you browse kt11.io, our servers automatically log Technical Data including your IP address, browser fingerprint, and session metadata. This collection occurs on every page visit, whether or not you are logged in.
• Cookies and Similar Technologies. kt11 uses first-party session cookies and analytics cookies to maintain your logged-in session and to understand aggregate usage patterns. Full details are provided in Section 7.
• Support Communications. When you contact kt11 support via email at [email protected], we collect and retain the content of those communications as Communications Data.
• Third-Party Sources. In limited circumstances, kt11 may receive data about you from third parties, for example where a payment provider flags a transaction as suspicious, or where a fraud-prevention service provider identifies a risk signal associated with your IP address or device.

4 Purpose & Legal Basis for Processing

kt11 processes Personal Data only where there is a lawful basis for doing so. The table below sets out our primary processing purposes and the corresponding legal basis:

Where kt11 relies on legitimate interest as a legal basis, we have assessed that our interests do not override your fundamental rights and freedoms, particularly given the security-focused nature of the processing.

Where we rely on consent — for example, for promotional email communications — you may withdraw that consent at any time by contacting [email protected] (plain text — not a link). Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5 Data Retention

kt11 retains Personal Data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Identity Data — retained for the lifetime of your Account and for a minimum of 5 years following Account closure, to meet anti-money laundering and fraud investigation obligations.
• Financial Data — transaction records are retained for a minimum of 5 years from the date of the transaction to comply with financial record-keeping requirements.
• KYC Documents — retained for a minimum of 5 years following Account closure or the date of the last transaction, whichever is later.
• Technical and Usage Data — retained for up to 24 months in identifiable form, after which it is anonymised or deleted.
• Communications Data — support correspondence is retained for up to 3 years from the date of the last communication in a thread.
• Responsible Gaming Data — self-exclusion records and related data are retained for the full duration of the exclusion period plus 5 years thereafter, to prevent re-registration during an active exclusion.

Upon expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. Anonymised data (which can no longer identify any individual) may be retained indefinitely for aggregate statistical purposes.

6 Data Sharing & Disclosure

kt11 does not sell, rent, or trade your Personal Data to any third party for marketing or commercial purposes. We share Personal Data only in the following limited circumstances:

• Payment Processors. Financial Data is shared with bKash, Nagad, Rocket, and Upay solely to the extent necessary to process your deposit or withdrawal instruction. Each provider operates under its own privacy policy and data protection framework.
• Game Providers. When you play a game hosted by a third-party studio (such as Pragmatic Play, Evolution Gaming, Ezugi, or Spribe), your Account identifier and game session data are transmitted to that provider to facilitate the game session. No additional Personal Data is shared beyond what is technically necessary.
• Fraud and Security Services. kt11 may share Technical Data and limited Identity Data with fraud-prevention and identity verification service providers to identify and prevent fraudulent activity on the platform.
• Legal and Regulatory Authorities. kt11 will disclose Personal Data to law enforcement agencies, regulatory bodies, or courts where required by applicable law, a valid legal process, or to protect the rights, property, or safety of kt11, its Players, or the public.
• Corporate Transactions. In the event of a merger, acquisition, or sale of substantially all of kt11's assets, Personal Data held by kt11 may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

In all cases where data is shared with third-party processors, kt11 maintains appropriate data processing agreements and takes reasonable steps to ensure those parties handle your data in accordance with applicable standards.

7 Cookies & Tracking Technologies

kt11 uses the following categories of cookies and similar tracking technologies on the kt11.io platform:

• Strictly Necessary Cookies. These cookies are essential for the operation of the kt11 platform. They enable core functionality such as maintaining your logged-in session, remembering your language preference, and processing transactions. These cookies cannot be disabled without rendering the platform non-functional.
• Analytics Cookies. kt11 uses first-party analytics tools to collect aggregate, anonymised data about how Players interact with the platform — including pages visited, time spent, navigation paths, and error events. This data helps us improve the platform experience. Analytics data is not linked to your identity unless you are logged in.
• Functionality Cookies. These cookies remember your preferences on the platform, such as game display settings and notification preferences, to personalise your experience on return visits.
• Security Cookies. Short-lived security tokens are used to protect against cross-site request forgery (CSRF) and session hijacking. These are automatically deleted when your browser session ends.

kt11 does not use third-party advertising cookies, behavioural tracking cookies, or cross-site tracking pixels. We do not participate in any advertising network that would place tracking technologies on kt11.io without your explicit consent.

You may control cookie behaviour through your browser settings. Disabling strictly necessary cookies will impair your ability to use the platform. Disabling analytics or functionality cookies will not prevent you from accessing core platform features.

8 Data Security

kt11 takes the security of your Personal Data seriously and implements a layered security architecture to protect against unauthorised access, disclosure, alteration, or destruction:

• Encryption in Transit. All data transmitted between your device and kt11.io is encrypted using 256-bit TLS/SSL encryption. Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Encryption at Rest. Sensitive data fields — including password hashes, identity document copies, and financial account references — are encrypted at rest on kt11's secured servers using AES-256 encryption.
• Access Controls. Access to Personal Data within kt11's internal systems is restricted on a strict need-to-know basis. Privileged access is protected by multi-factor authentication and comprehensive audit logging.
• Intrusion Detection. kt11 operates continuous automated monitoring and intrusion detection systems that flag anomalous activity patterns for immediate review by the security team.
• Penetration Testing. The kt11 platform undergoes periodic security assessments and penetration testing by independent security professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident Response. In the event of a data security incident that poses a risk to Players' Personal Data, kt11 will notify affected Players without undue delay and will take all reasonable steps to contain and remediate the incident.

9 Your Rights

As a kt11 Player, you hold the following rights in relation to your Personal Data. To exercise any of these rights, please contact kt11 at [email protected] (plain text — not a link) with a clear description of your request. kt11 will respond within 30 days of receiving a verifiable request:

kt11 will not charge a fee for responding to a rights request unless the request is manifestly unfounded or excessive. Where a fee is applicable, kt11 will notify you before processing the request.

10 Children's Privacy

kt11 operates exclusively for adults. The minimum age requirement on the kt11 platform is 21 years. kt11 does not knowingly collect, store, or process Personal Data from any individual under the age of 21.

If kt11 discovers or is notified that Personal Data of an individual under 21 has been collected — whether through misrepresentation during registration or any other means — kt11 will immediately close the relevant Account, delete all associated Personal Data to the extent not required by legal retention obligations, and forfeit any balance held in that Account in accordance with the Terms & Conditions.

If you have reason to believe that a person under the age of 21 has registered on kt11 or that Personal Data of a minor is being processed by kt11, please contact [email protected] (plain text — not a link) immediately so that appropriate action can be taken.

11 Third-Party Links

The kt11 platform may contain references or links to third-party websites or services — for example, links to payment provider information pages or game studio terms. This Privacy Policy applies solely to Personal Data processed by kt11 on the kt11.io platform.

kt11 has no control over, and accepts no responsibility for, the privacy practices or content of any third-party website. When you leave the kt11 platform and visit a third-party site, we strongly encourage you to review that site's privacy policy before providing any Personal Data.

12 Changes to This Privacy Policy

kt11 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will publish an updated version of this Policy on kt11.io with a revised "Last Updated" date and, where the changes are significant, notify registered Players via a notice displayed on the Platform.

The version published on kt11.io at any given time is the current and binding version of this Privacy Policy. We encourage you to review this Policy periodically. Your continued use of the kt11 platform following publication of an updated Privacy Policy constitutes your acknowledgement of the changes.

If you disagree with any material change to this Policy, you may close your Account in accordance with Section 4.6 of the kt11 Terms & Conditions by contacting [email protected] (plain text — not a link).

13 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your Personal Data by kt11, please contact the kt11 Data Support team:

If you are not satisfied with kt11's response to your privacy concern, you have the right to escalate your complaint to the relevant data protection authority or regulatory body applicable in your jurisdiction. kt11 will cooperate fully with any such authority in the resolution of a complaint.