1ee Privacy Policy

This Privacy Policy ("Policy") describes how 1ee ("1ee", "we", "us", "our") collects, stores, uses, and shares personal data relating to individuals ("you", "Player", "User") who access or use the 1ee online gaming platform accessible at 1ee.app, including all associated subdomains, mobile interfaces, and affiliated services operated under the 1ee brand.

This Policy applies to all personal data processed by 1ee in connection with your use of the platform, including data collected during account registration, KYC identity verification, financial transactions, gameplay, customer support interactions, and marketing communications.

This Policy must be read alongside the 1ee Terms & Conditions and the 1ee Responsible Gaming Policy. Together, these three documents form the complete framework governing your relationship with the platform. All three documents are published at 1ee.app and are accessible at all times.

For the purposes of this Policy, the data controller responsible for your personal data is the legal entity that operates the 1ee platform under its international gaming license. The platform is operated by 1ee and accessible at 1ee.app.

For all data protection queries, subject access requests, and privacy-related complaints, you may contact the 1ee Data Protection team using the contact details provided in Section 15 of this Policy.

1ee collects the following categories of personal data from players in the course of operating its platform:

1ee does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data (beyond responsible gaming self-disclosed information), or biometric data, except where strictly required by KYC regulations applicable to the gaming license.

1ee collects personal data through the following channels:

• Direct submission: Data you provide when registering your 1ee account, completing KYC verification, making deposits or withdrawals, or contacting the support team.
• Automated collection: Data collected automatically when you access the platform, including IP address, device identifiers, session data, and cookies (see Section 10).
• Third-party identity verification: KYC data verified through third-party identity checking services using the documents you provide. These services return a verified/unverified result and do not provide additional data beyond what you submitted.
• Payment processors: Transaction confirmation data returned by JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and other payment processing partners used on the platform.
• Game and sports data providers: Technical event data from the gaming and odds providers that supply 1ee's casino games and sportsbook markets.

1ee processes your personal data only where a valid legal basis exists to do so. The legal bases relied upon by 1ee are as follows:

• Contractual necessity: Processing required to perform the contract between you and 1ee — including operating your account, processing payments, and providing gaming services.
• Legal obligation: Processing required to comply with applicable law, including KYC identity verification, AML transaction monitoring, and record-keeping obligations imposed by 1ee's gaming license.
• Legitimate interests: Processing carried out in pursuit of 1ee's legitimate business interests, including fraud prevention, platform security, and improving user experience — where those interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications and optional personalization features, where your explicit consent has been obtained. You may withdraw this consent at any time.

1ee uses the personal data it collects for the following purposes:

• Creating, verifying, and managing your 1ee player account.
• Processing PKR deposits and withdrawals through JazzCash, EasyPaisa, and other supported payment methods.
• Conducting KYC identity and age verification to ensure compliance with the 21+ requirement and applicable regulations.
• Monitoring transactions for fraud, money laundering, and terrorist financing activity in accordance with AML obligations.
• Operating the responsible gaming tools on your account, including deposit limits, self-exclusion, and session alerts.
• Providing customer support and resolving account disputes or complaints.
• Sending transactional communications including deposit confirmations, withdrawal updates, and security alerts.
• Sending promotional communications, offers, and PSL-season bonuses — only where you have given consent and not opted out.
• Analyzing platform usage data in aggregated, anonymized form to improve the 1ee product and user experience.
• Complying with legal obligations including audit requirements and regulatory reporting.

1ee does not sell your personal data to any third party. Data may be shared with the following categories of third parties, strictly for the purposes described and under binding contractual data protection obligations:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and cryptocurrency network processors — solely for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party identity verification services used to check CNIC and passport documents during account verification.
• Game content providers: The suppliers of casino games, live dealer tables, and fish games available on the 1ee platform. Game event data is shared with providers for the purpose of resolving technical disputes and auditing game outcomes.
• Cloud infrastructure providers: Server, storage, and database infrastructure providers used to host the 1ee platform. All infrastructure providers are bound by confidentiality and data security obligations.
• Regulatory authorities: Gaming regulators, financial intelligence units, and law enforcement agencies — where 1ee is legally obligated to report or provide data, for example in connection with an AML investigation or a regulatory audit.
• Legal and compliance advisors: Legal counsel and compliance consultants engaged by 1ee — under strict professional confidentiality obligations.

Where data is shared with a third-party processor, 1ee enters into a written data processing agreement that obligates the processor to handle personal data only as instructed by 1ee, to maintain appropriate security measures, and to return or delete data upon termination of the agreement.

Some of the third-party service providers used by 1ee operate outside Pakistan. Where your personal data is transferred outside Pakistan to a country that does not maintain an equivalent standard of data protection, 1ee ensures that appropriate safeguards are in place prior to any transfer.

Safeguards used by 1ee for international data transfers include:

• Standard contractual clauses or equivalent binding legal instruments with the receiving party.
• Transfer to jurisdictions recognized as providing an adequate level of data protection by the relevant regulatory authority.
• Binding corporate rules where transfers are made within a corporate group subject to such rules.

You may request details of the specific safeguards in place for any particular third-party transfer by contacting the 1ee Data Protection team at the address set out in Section 15.

1ee retains personal data only for as long as is necessary for the purposes for which it was collected, unless a longer retention period is required by applicable law. The following retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of 5 years following account closure, as required by AML and gaming license obligations.
• Financial transaction records: Retained for a minimum of 7 years following the date of each transaction, in accordance with applicable financial record-keeping requirements.
• Gaming history: Retained for the duration of your account and for at least 5 years following account closure, for audit and dispute resolution purposes.
• Customer support records: Retained for 3 years following the closure of each support interaction.
• Marketing consent records: Retained for 3 years following withdrawal of consent or last marketing interaction, whichever is later.
• Technical and session data: Retained for 12 months from the date of collection, subject to ongoing security and fraud investigation requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with an individual. Anonymized aggregate data may be retained indefinitely for statistical and business intelligence purposes.

1ee uses cookies and similar tracking technologies on the 1ee.app platform. Cookies are small text files stored on your device that allow the platform to recognize your browser, maintain your session, and deliver a consistent user experience.

The following categories of cookies are used on the 1ee platform:

• Strictly necessary cookies: Essential for the platform to function. These enable your login session, account balance display, and secure payment processing. These cookies cannot be disabled without breaking core platform functionality.
• Performance and analytics cookies: Collect anonymized data about how players use the platform — including page load times, navigation patterns, and error events — to help 1ee improve the product. No personally identifiable data is collected via these cookies.
• Functional cookies: Remember your preferences such as language settings, display options, and notification preferences to provide a personalized experience on return visits.
• Security cookies: Used for fraud detection, device fingerprinting, and session integrity monitoring to protect your account against unauthorized access.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the core 1ee platform, though some personalization features may be affected. Strictly necessary and security cookies are required for the platform to operate and cannot be disabled.

The 1ee platform is strictly for adults aged 21 years and above. 1ee does not knowingly collect, store, or process personal data from individuals under the age of 21. The platform implements age verification controls at the point of registration and through the KYC identity verification process to enforce this requirement.

If you have reason to believe that a person under 21 has registered for a 1ee account, please contact the 1ee support team immediately at the contact details provided in Section 15. We will investigate and take appropriate action within 24 hours.

1ee implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 1ee servers.
• AES-256 encryption for all personal and financial data stored on 1ee infrastructure.
• Role-based access controls ensuring that 1ee staff can only access personal data relevant to their specific job function.
• Mandatory multi-factor authentication for all 1ee staff accessing production systems or player data.
• Automated intrusion detection and prevention systems monitoring for unauthorized access attempts.
• Regular independent security audits and penetration testing of the 1ee platform and infrastructure.
• Segregation of player funds in accounts separate from 1ee operational funds, reducing financial exposure in the event of a breach.
• Formal incident response procedures with defined escalation paths and notification timelines in the event of a data breach.

Notwithstanding these measures, no system is entirely immune to security risks. You play an important role in keeping your account secure by using a strong, unique password, enabling SMS OTP two-factor authentication, and not sharing your login credentials with any third party.

You may exercise any of the data rights described in the "Your Data Rights" section above by submitting a written request to the 1ee Data Protection team using the contact details in Section 15. To protect the security of your personal data, 1ee will verify your identity before processing any data rights request.

The following timelines apply to data rights requests:

• Acknowledgement of receipt within 2 business days of submission.
• Initial identity verification completed within 5 business days.
• Substantive response and data delivery within 30 calendar days of identity verification.
• Extension of up to a further 60 days may be applied in complex cases — you will be notified within the initial 30-day period if an extension is required and the reasons for it.

There is no charge for processing data rights requests unless requests are manifestly unfounded or excessive — for example, repetitive requests covering the same data with no material change in circumstances. In such cases, 1ee may charge a reasonable fee or decline to act, having notified you of the reason.

1ee may update this Privacy Policy from time to time to reflect changes in the platform's data practices, applicable law, or regulatory requirements. When material changes are made, 1ee will notify registered players via the email address associated with their account and will update the "Last updated" date at the top of this page.

Minor updates that do not materially affect how 1ee processes personal data may be made without individual notification. The current version of this Policy will always be accessible at 1ee.app/privacy-policy.

Continued use of the 1ee platform following the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with any amendment, please contact the 1ee support team to discuss account closure and withdrawal of remaining balances.

For all privacy-related queries, subject access requests, data rights requests, or concerns about how 1ee processes your personal data, please contact the 1ee Data Protection team. The support team is available 24 hours a day, 7 days a week, via live chat on the 1ee platform.

You may also submit written privacy queries by email. The 1ee support email address is displayed in the footer of every page on the 1ee.app website.

If you are not satisfied with 1ee's response to your privacy complaint, you have the right to escalate the matter to 1ee's gaming regulator. Details of the formal complaints escalation procedure are provided in the response to your initial complaint.