Privacy Policy — ZT77 Platform

This Privacy Policy (hereinafter "the Policy") describes how ZT77 — operating the online betting and casino platform accessible at zt77.cam and associated subdomains (collectively, "the Platform") — collects, processes, stores, shares and protects the personal data of individuals who access or use the Platform ("Users", "you" or "your").

ZT77 is committed to handling personal data responsibly, with full transparency and in accordance with applicable data protection principles. We do not collect data beyond what is reasonably necessary for the purposes set out in this Policy, and we do not use your data in ways inconsistent with those purposes.

This Policy applies to all personal data collected through:

• Account registration and the ongoing use of your ZT77 account;
• KYC (Know Your Customer) verification processes;
• Deposit, wagering and withdrawal transactions;
• Customer support interactions via live chat or email;
• Technical interactions with the Platform, including browser and device data collected automatically.

In this Privacy Policy, the following terms carry the meanings defined below:

ZT77 acts as the Data Controller in respect of all personal data collected through the Platform. As Data Controller, ZT77 determines the purposes for which and the manner in which your personal data is processed.

Where ZT77 engages third-party service providers — such as payment processors, KYC verification platforms or analytics providers — those parties act as Data Processors operating under ZT77's written instructions and under contractual obligations that include appropriate data protection safeguards.

ZT77 does not designate or appoint a local data representative in Pakistan. Users in Pakistan interact with the Platform and provide their personal data on the basis of ZT77's published policies. ZT77 acknowledges that the intersection of data protection obligations and Pakistan's legal environment is complex; users are encouraged to seek independent advice regarding their data rights under applicable Pakistani law.

ZT77 collects personal data in the following categories, depending on how you interact with the Platform:

4.1 Registration and Account Data

• Full legal name;
• Email address;
• Date of birth;
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar);
• Username and encrypted password hash;
• Phone number (where provided).

4.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Pakistani CNIC, passport);
• Proof of address documentation (e.g., utility bill, bank statement);
• Facial image or liveness check data where required by the verification process;
• KYC status and verification outcome.

4.3 Financial and Transaction Data

• Payment method type and partial identifier (e.g., last four digits of a card, wallet account reference);
• Deposit amounts, withdrawal requests and transaction history;
• Currency denomination (typically PKR or equivalent);
• Transaction timestamps and confirmation references.

ZT77 does not store full payment card numbers. Card processing is handled by PCI-DSS-compliant third-party payment processors.

4.4 Usage and Behavioural Data

• Pages visited, features used and session durations;
• Game history, wager amounts and betting patterns;
• Login timestamps and IP address logs;
• Responsible gambling tool usage (e.g., deposit limits set, self-exclusion requests).

4.5 Device and Technical Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system version and browser type;
• Screen resolution and language settings;
• Cookie identifiers and session tokens.

4.6 Communications Data

• Records of customer support interactions via live chat or email;
• The content of support requests, complaints and dispute submissions.

ZT77 collects personal data through the following channels and mechanisms:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support or respond to any survey or communication from ZT77;
• Automatically during Platform use — through cookies, server logs, session tracking and analytics tools that capture device information, page interactions and usage patterns as you browse the Platform;
• From third-party service providers — including KYC verification platforms (which return verification status and document authenticity flags), payment processors (which return transaction confirmations) and fraud prevention services (which return risk scores based on behavioural analysis);
• From publicly available sources — such as sanctions lists, politically exposed persons (PEP) databases and public records, where required for AML compliance purposes.

ZT77 processes personal data on the following legal bases:

ZT77 uses the personal data it collects for the following purposes:

• Account management: Creating, maintaining and administering your registered account, including processing login sessions and account settings changes;
• Service delivery: Processing deposits, managing your real money and bonus balances, settling wager results and processing withdrawal requests;
• Identity and age verification: Confirming that you meet the minimum eligibility requirements before allowing access to funded account features;
• Fraud and AML detection: Monitoring transactions and account behaviour for indicators of fraudulent activity, money laundering, bonus abuse or multi-accounting;
• Customer support: Responding to your support queries, resolving disputes, processing account closure requests and handling complaints;
• Responsible gambling: Identifying usage patterns that may indicate problem gambling and enabling the delivery of responsible gambling tools such as deposit limits, session reminders and self-exclusion features;
• Platform improvement: Analysing aggregated, anonymised usage data to improve the Platform's performance, design and content;
• Legal and regulatory compliance: Meeting applicable obligations in ZT77's operating jurisdiction, including record-keeping and regulatory reporting requirements;
• Marketing (with consent only): Sending promotional communications, bonus notifications or platform updates where you have explicitly opted in to receive them.

ZT77 does not sell, rent or trade your personal data. We may share your personal data with the following categories of recipients only where strictly necessary and on the basis of appropriate data protection agreements:

• Payment processors: To facilitate deposit and withdrawal transactions. Payment processors (including those handling transactions via services familiar in Pakistan such as Easypaisa, JazzCash or bank transfer through HBL, UBL, Meezan Bank or Bank Alfalah channels) receive only the minimum data required to process the specific transaction. These references are not to imply that any payment provider endorses gambling;
• KYC and identity verification providers: To verify your identity, age and document authenticity during the verification process;
• Fraud prevention and AML service providers: To screen transactions and account activity against risk indicators and sanctions lists;
• Analytics providers: To receive aggregated and anonymised usage statistics for Platform optimisation purposes. Individual user data is not shared with analytics providers in identifiable form;
• Legal and regulatory authorities: Where required by law, court order or a legitimate request from a law enforcement authority with appropriate jurisdiction. ZT77 will notify affected users where legally permitted to do so;
• Professional advisers: Legal counsel, accountants and auditors acting in an advisory capacity, subject to professional confidentiality obligations.

All third-party data processors engaged by ZT77 are required to process personal data solely for the purposes specified by ZT77 and to maintain appropriate technical and organisational security measures.

ZT77 may transfer your personal data to countries outside your country of residence, including to countries where the data protection laws may differ from those in your jurisdiction. This is inherent in the operation of a global online platform and in the engagement of internationally operating service providers such as payment processors and KYC verification platforms.

Where personal data is transferred internationally, ZT77 takes reasonable steps to ensure that appropriate safeguards are in place, including:

• Transfers to recipients in jurisdictions that are subject to adequacy determinations by applicable data protection authorities;
• The use of contractual clauses that impose data protection obligations on the recipient equivalent to those in ZT77's own policies;
• Transfers to certified recipients under recognised international data transfer frameworks where applicable.

ZT77 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal, regulatory or contractual obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised so that it can no longer be associated with a specific individual. Requests for earlier deletion will be considered under the right of erasure provisions in Section 12.

ZT77 uses cookies and similar technologies on the Platform to ensure the Platform functions correctly, to maintain your session, and to collect aggregated analytics data to improve the user experience. The following categories of cookies are in use:

11.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They maintain your login session, preserve your language and settings preferences, and support security features such as CSRF protection. These cookies cannot be disabled without breaking core Platform functionality.

11.2 Analytics Cookies

Analytics cookies collect aggregated, anonymised information about how users interact with the Platform — which pages are visited most often, where users encounter issues and how long sessions last. This data is used solely to improve the Platform. Where third-party analytics tools are used, data is anonymised before transmission.

11.3 Functional / Preference Cookies

These cookies remember your preferences — such as display settings, notification preferences or responsible gambling tool configurations — so that you do not need to re-enter them on each visit. You may choose to disable these cookies without affecting core Platform access.

11.4 Managing Your Cookie Preferences

You may manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will prevent you from logging into your ZT77 account. Instructions for managing cookies in common browsers are available through the browser's own help documentation.

ZT77 does not deploy third-party advertising cookies, tracking pixels for retargeting or cross-site tracking technologies that build profiles for advertising purposes.

Subject to applicable data protection law and certain conditions, you have the following rights in relation to your personal data held by ZT77. To exercise any of these rights, contact us at [email protected] with the subject line "Data Subject Request". ZT77 will respond within 30 calendar days.

ZT77 is strictly an 18+ platform. The Platform is not directed at, and is not intended for use by, any individual under the age of 18 years — or the higher minimum age required by the operator's licence jurisdiction or applicable local law, whichever is greater.

ZT77 does not knowingly collect personal data from minors. KYC verification procedures are in place specifically to prevent underage access. If ZT77 discovers or is notified that it has inadvertently collected personal data from a minor, it will immediately close the associated account, delete the data (subject to any minimum legal retention requirements related to the age verification incident) and will not process any transactions made by the minor.

If you believe that a minor has created a ZT77 account, please contact us immediately at [email protected] so that the matter can be investigated and resolved promptly.

ZT77 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration or disclosure. These include:

• TLS encryption: All data transmitted between your device and the Platform is encrypted using TLS (Transport Layer Security) over HTTPS;
• Password hashing: Passwords are never stored in plain text. ZT77 stores only cryptographic hashes of passwords using industry-standard hashing algorithms;
• Access controls: Access to personal data within ZT77's systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations;
• Payment security: Full payment card numbers are never stored by ZT77. Card processing is handled by PCI-DSS-compliant payment processors;
• KYC document security: Identity documents submitted for verification are processed via a secure HTTPS portal and are not retained beyond the period required for verification and compliance purposes;
• Incident response: ZT77 maintains a security incident response process to detect, contain and respond to data breaches. Affected users will be notified where required by applicable law.

While ZT77 takes reasonable precautions to protect your data, no internet transmission or digital storage system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for ensuring that your own device and network are adequately secured.

The ZT77 Platform may from time to time reference or provide information about third-party services — including payment providers familiar in the Pakistani market such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah. These references are provided as contextual information only and do not constitute endorsement, affiliation or confirmation of support for gambling by those institutions.

ZT77 is not responsible for the privacy practices, data handling policies or security measures of any third-party service provider. If you interact with a third-party payment provider, KYC platform or any other external service as part of using ZT77, you do so subject to that third party's own privacy policy. ZT77 encourages you to review the privacy policies of any third-party services you use in connection with your ZT77 account.

ZT77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. The "Last Updated" date at the top of this page indicates when the current version was published.

Where amendments are material — meaning they significantly affect your rights or the way your data is processed — ZT77 will notify registered users by email to the address associated with their account, or by displaying a prominent notice on the Platform, at least 14 days before the changes take effect.

Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree to the amended Policy, you should cease using the Platform and contact support to close your account before the effective date of the changes.

If you have any questions or concerns about this Privacy Policy, wish to exercise any of your data rights, or wish to submit a privacy-related complaint, please contact the ZT77 privacy team using the details below.

If you are dissatisfied with ZT77's response to a privacy complaint, you may have the right to escalate your complaint to a relevant data protection supervisory authority in your jurisdiction. The applicable authority will depend on your country of residence and the laws that govern ZT77's data processing activities. ZT77 will cooperate with any such investigation in good faith.