111a Privacy Policy – Your Data Protected

1Who Is the Data Controller

The controller of members' personal data on the platform is 111a, operator of the 111a.best website. As the data controller, 111a determines the purposes and means of processing the personal data collected in accordance with the General Data Protection Law (LGPD — Law 13.709/2018).

The Data Protection Officer (DPO) of 111a can be reached by email at suporte@111a.best, with the subject line "Data Privacy". All requests related to personal data — access, correction, deletion, portability, or withdrawal of consent — must be directed to this channel and will be answered within 15 business days.

2What Data We Collect

The 111a collects personal data in the following categories, according to the purpose of use:

The 111a collects only the data strictly necessary for each purpose — the data minimization principle established by the LGPD. We do not collect sensitive data such as racial origin, political opinion, health information, or biometrics, except where required by a specific legal obligation.

3How and Why We Use Your Data

Personal data collected by 111a are used solely for the following purposes, each with its corresponding legal basis under the LGPD:

• Account operation and service delivery: account creation and management, bet processing, live casino games, bonus crediting, and the VIP Program. Legal basis: contract performance (Art. 7, V).
• Payment processing: deposits via Pix, boleto bancário, credit and debit cards, PicPay, Mercado Pago, and TED; processing of withdrawals to bank accounts in Brazil (Nubank, Itaú, Bradesco, Banco do Brasil, and others). Legal basis: contract performance (art. 7º, V).
• Identity verification (KYC): identity confirmation, age verification (18+), prevention of multiple accounts using the same CPF. Legal basis: legal obligation and legitimate interest (Art. 7, II and IX).
• Fraud and money laundering prevention: monitoring of unusual transactions, betting behavior analysis, and compliance with Banco Central do Brasil regulations. Legal basis: legal obligation and legitimate interest (art. 7, II and IX).
• Member support: support via chat, email, and interaction logging for quality control purposes. Legal basis: contract performance and legitimate interest (art. 7, V and IX).
• Service communications: transactional emails regarding deposits, withdrawals, bet confirmations, security alerts, and Terms updates. Legal basis: contract performance (Art. 7, V).
• Promotional communications: emails and notifications about promotions, bonuses, and news from 111a. Legal basis: consent (art. 7º, I). You may withdraw this consent at any time in your account settings.
• Platform improvement: analysis of browsing behavior to improve the user experience, technical stability, and the development of new features. Legal basis: legitimate interest (art. 7, IX).

The 111a does not use your data for any purpose beyond those listed above. If we wish to use your data for a new purpose, you will be notified and, where required, we will request fresh consent.

4Data Sharing with Third Parties

The 111a may share members' personal data with third parties only in the following situations, each with a defined legal basis:

• Payment processors: financial data is shared with Pix operators, card processors, PicPay, Mercado Pago, and banking institutions strictly to carry out transactions requested by the member. These partners act as data processors under a confidentiality agreement.
• Identity verification providers: for KYC verification purposes, document data may be processed by companies specializing in biometrics or document validation, always under a data processing agreement compatible with the LGPD.
• Casino game providers: username and session history are shared with game providers (slots, live casino, crash games) to ensure accurate history display and dispute resolution. Full identification data is not shared with game providers.
• Regulatory and judicial authorities: when required by law, court order, or request from a competent authority, 111a may be required to provide members' personal data. In such cases, we share only the minimum necessary to fulfill the legal request.
• Auditors and legal advisors: professionals involved in compliance audits, legal disputes, or regulatory proceedings may have access to anonymized data or, where necessary, to identifiable data, always under a confidentiality obligation.

The 111a never sells, rents, exchanges, or transfers members' personal data to third parties for commercial or marketing purposes. No data is shared with companies that have no direct relationship with the operation of the platform.

5Data Storage and Security

The personal data of members of 111a are stored on servers located in Brazil or in countries that provide an adequate level of data protection as assessed by the National Data Protection Authority (ANPD). All data in transit is protected by TLS 1.3 encryption. Data at rest is stored with AES-256 encryption.

The technical and administrative security measures adopted by 111a include:

• SSL/TLS encryption across all communications between clients and servers;
• Two-factor authentication (2FA) available to all members;
• Role-based access control — staff can only access the data required for their specific role;
• 24-hour security monitoring with intrusion detection and automated alerts;
• Data access logs with periodic auditing;
• Penetration testing and vulnerability assessments conducted periodically by an independent firm;
• Encrypted backups retained for a minimum of 90 days.

In the event of a security incident that may cause significant risk or harm to members, 111a will notify the ANPD and affected members within the legal deadline (up to 3 business days after becoming aware of the incident), as required by the LGPD. The notification will include the nature of the incident, the data affected, the measures taken, and guidance for data subjects.

6How Long We Retain Your Data

The 111a retains personal data for as long as necessary for each purpose, following these criteria:

• Active account data: kept for as long as the account remains active. If an account is inactive for more than 24 months with no deposits or bets, the member is notified by email before any action is taken on their data.
• Financial and transaction data: retained for a minimum of 5 years after each transaction, in accordance with financial compliance obligations and Brazilian Central Bank regulations.
• Identity verification (KYC) data: retained for a minimum of 5 years after account closure, in compliance with anti-money laundering requirements (Law 9.613/1998).
• Betting and game history: retained for a minimum of 2 years for dispute resolution purposes and 5 years for tax and regulatory compliance.
• Support data: support history retained for 2 years after each case is closed.
• Marketing consent data: retained for as long as consent remains in effect and for up to 5 years after its withdrawal, for the purpose of demonstrating the lawfulness of use.

Once retention periods have elapsed, data is securely and permanently deleted, or anonymized for use in statistical analysis without individual identification.

7Cookies & Tracking Technologies

The 111a uses cookies and similar technologies to enhance the platform experience. The cookies used fall into the following categories:

• Essential cookies: required for the platform's basic operation — session management, authentication, and security. They cannot be disabled without affecting access to the platform.
• Preference cookies: remember your interface settings, language, and browsing preferences so you don't have to reconfigure the platform on every visit.
• Analytical cookies: collect aggregated, anonymized information about how members navigate the platform — pages visited, session duration, errors encountered. Used solely to improve the platform. Data is anonymized before any analysis.
• Security cookies: detect suspicious behavior, multiple accounts accessing from the same device, and fraud attempts.

The 111a does not use third-party behavioral advertising cookies. You can manage non-essential cookies in your browser settings. Disabling preference cookies may affect your platform experience, but will not block your access.

8Your Rights as a Data Subject (LGPD)

The LGPD grants you, as a personal data subject, the following rights regarding your data held by 111a:

• Confirmation and access: find out whether 111a processes your data and obtain a copy of the information held about you.
• Correction: request the correction of incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion: request that data which is unnecessary, excessive, or processed in violation of the LGPD be anonymized, blocked, or deleted.
• Portability: request the portability of your data to another service or product provider, in accordance with ANPD regulations.
• Data sharing information: find out which public and private entities 111a has shared your data with.
• Withdrawing consent: withdraw consent for processing based on consent (such as promotional communications) at any time, at no cost.
• Objection: object to data processing carried out on the basis of legitimate interest when there is a justifiable reason to do so.
• Review of Automated Decisions: request human review of automated decisions made based on your data, such as account blocks or withdrawal denials.

To exercise any of these rights, contact our DPO by email at suporte@111a.best with the subject line "LGPD Rights – [your specific right]". The 111a will respond within 15 business days and may request identity verification before processing the request.

If you believe your rights have been violated after exhausting all direct resolution attempts with 111a, you may file a complaint with the National Data Protection Authority (ANPD) at gov.br/anpd.

9Consent and How to Withdraw It

When you register on 111a, you consent to the processing of your data for the essential purposes described in this policy (account operation, payments, identity verification, support). This consent is required to use the platform — without it, you cannot create or maintain an active account.

Consent to promotional communications (emails and notifications about promotions, bonuses, and news from 111a) is separate and optional. You can manage it at any time in your account settings, under "Communication Preferences", without any impact on your access to the platform's core features.

Revoking consent for promotional communications does not affect the lawfulness of processing carried out before the revocation. After revocation, the 111a will stop sending promotional communications within 48 hours. Transactional emails — such as deposit confirmations, withdrawal alerts, and security notices — will continue to be sent as they have a distinct legal basis from consent.

10Account Security & Member Responsibilities

The security of your account at 111a is a shared responsibility. The platform implements all the technical measures described in this policy, but you also play a key role in protecting your own data:

• Use a strong, unique password for your 111a account 111a — do not reuse passwords from other services;
• Enable two-factor authentication (2FA) in your account dashboard;
• Never share your login credentials with others, including family members or friends;
• Access the platform only over trusted Wi-Fi networks or your mobile data connection;
• If you suspect unauthorized access, change your password immediately and contact 111a;
• Log out of your account when using shared or public devices.

The 111a never asks for passwords, authentication codes, or full financial details via email, chat, or phone. If you receive a request of this kind claiming to be from 111a, disregard it and report it to support immediately.

11Minors

The platform 111a is strictly intended for users aged 18 and over. We do not knowingly collect personal data from minors. If we identify that an account was created by a minor, it will be closed immediately, all data will be deleted, and any deposited funds will be returned to the original payment method following verification.

If you believe a minor has created an account at 111a, please contact us immediately at suporte@111a.best. We will handle your case with priority and full confidentiality.

12Changes to This Privacy Policy

The 111a may update this Privacy Policy periodically to reflect changes in data processing practices, Brazilian legislation, or platform features. Any changes will be communicated by email to the address on file and via a prominent notice on the platform at least 7 calendar days before taking effect.

For changes that represent a significant shift in your rights or in the purposes for which your data is used, fresh consent may be required before you continue using the platform. In such cases, the notice will clearly explain what has changed and what is required of the member.

The current version of this policy is always the one published at 111a.best/privacy-policy. The date of the last update is indicated at the top of this page.