This Privacy Policy explains how ZC99 collects, processes, stores and protects personal data provided by users of the platform. Please read this document carefully. By using the ZC99 platform you confirm that you have read and understood the practices described here.
ZC99 (hereinafter referred to as "ZC99", "the Platform", "we", "us" or "our") is committed to protecting the personal data of all individuals who access or use the ZC99 website located at https://zc99.cam and any associated services, applications and features made available through the platform (collectively, "the Services").
This Privacy Policy (hereinafter referred to as "Policy") sets out in detail the categories of personal data we collect, the purposes for which that data is processed, the legal bases that justify such processing, the parties with whom data may be shared, and the rights available to data subjects in relation to their personal information.
This Policy should be read in conjunction with ZC99's Terms & Conditions, which govern the broader contractual relationship between you and the Platform. By creating an account or using the Services, you acknowledge that you have read and understood this Policy and consent to the data practices described herein to the extent that consent is required as a legal basis for processing.
Pakistani Users — Jurisdictional Note: ZC99 does not claim to hold authorisation, licensing or endorsement from any Pakistani governmental authority, including the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any provincial regulatory body. This Policy is not legal advice. Users in Pakistan should obtain independent legal advice as to the lawfulness of their participation in online gaming and the applicable data protection framework in their jurisdiction before registering or depositing.
For the purposes of this Privacy Policy, the following definitions apply:
ZC99 acts as the Data Controller in respect of personal data collected and processed through the platform. ZC99 operates under applicable international licensing frameworks and processes personal data in accordance with the data protection laws applicable in its operating jurisdiction.
Where ZC99 engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification services or analytics providers — those parties act as Data Processors subject to binding contractual data processing agreements that restrict their use of personal data to the specific purposes for which it was shared.
For all data protection enquiries, User rights requests and complaints, please contact ZC99 using the details provided in Section 16 of this Policy.
ZC99 collects the following categories of personal data in connection with the operation of the platform and the provision of the Services:
Full legal name, date of birth, nationality, government-issued identity document numbers (such as Pakistani CNIC or passport number), and any additional identity information required for KYC compliance purposes.
Email address, telephone number and postal residential address. For users in Pakistan, this may include city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar) and associated postcode.
Deposit and withdrawal transaction records, payment method identifiers (such as partial bank account or wallet reference numbers), transaction amounts in PKR or other applicable currencies, and source-of-funds documentation where required under AML procedures.
Login timestamps, session durations, wagering history, game participation records, bonus usage, sports betting selections, responsible gambling tool settings and Account communication history.
IP address, browser type and version, device type and operating system, screen resolution, referring URL, and session cookies used to maintain login state and platform functionality.
The content of communications submitted to ZC99 support via live chat, email or the on-platform contact interface, including queries, complaints and dispute correspondence.
Special Category Data: ZC99 does not intentionally collect special category data (as defined in Section 2) from Users. If you voluntarily disclose health-related information in the context of a responsible gambling self-exclusion request or support query, that information will be treated with heightened confidentiality and used solely for the purpose for which it was disclosed.
ZC99 collects personal data through the following channels:
ZC99 processes personal data only where a valid legal basis exists under applicable data protection law. The following legal bases apply to ZC99's processing activities:
| Processing Activity | Legal Basis |
|---|---|
| Account registration and management | Performance of contract |
| Processing deposits and withdrawals | Performance of contract |
| KYC and identity verification | Legal obligation (AML/regulatory compliance) |
| Fraud detection and prevention | Legitimate interests of the Platform |
| Responsible gambling tool management | Legal obligation / legitimate interests |
| Marketing communications (opted-in) | Consent (withdrawable at any time) |
| Platform analytics and improvement | Legitimate interests of the Platform |
| Customer support and dispute resolution | Performance of contract / legitimate interests |
ZC99 processes personal data for the following specific purposes:
ZC99 does not sell, rent or trade personal data to third parties for their own marketing or commercial purposes. Personal data may be shared in the following limited and controlled circumstances:
ZC99 engages third-party service providers who process personal data on the Platform's behalf under binding data processing agreements. These include payment processing services, identity verification providers, customer support technology providers, fraud detection services, email delivery services and platform analytics providers. All such processors are contractually restricted from using personal data for any purpose other than the provision of their designated service to ZC99.
Where users interact with payment methods familiar in Pakistan — such as Easypaisa, JazzCash, Raast, and bank transfers through HBL, UBL, Meezan Bank, Bank Alfalah or other financial institutions — transaction data is processed by the relevant financial institution as an independent data controller subject to its own privacy terms. ZC99 does not control the data practices of third-party payment providers. The mention of these services on the ZC99 platform does not imply their endorsement of, or affiliation with, ZC99 or online gambling activity.
ZC99 may disclose personal data to regulatory authorities, law enforcement agencies, courts or other competent public bodies where required to do so by law, court order, regulatory direction or to protect the legal rights of the Platform or third parties.
In the event of a merger, acquisition, restructuring or sale of assets involving ZC99, personal data held by the Platform may be transferred to the successor entity as part of that transaction, subject to equivalent data protection standards being maintained.
Given the international nature of ZC99's operations and the global footprint of many of its service providers, personal data may be transferred to and processed in countries outside your country of residence, including countries that may not provide a level of data protection equivalent to that of your home jurisdiction.
Where such transfers occur, ZC99 takes reasonable steps to ensure that appropriate safeguards are in place — such as standard contractual clauses, binding corporate rules or equivalent mechanisms — to protect your personal data in accordance with the principles set out in this Policy.
ZC99 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy, and to comply with applicable legal, regulatory and licensing obligations. The following general retention principles apply:
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ZC99's internal data lifecycle management procedures.
Cookies are small text files placed on your device by a website during your browsing session. They allow the website to recognise your device, retain session state and collect usage analytics. ZC99 uses cookies and similar tracking technologies as part of its platform operation.
You may manage cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies may impair your ability to use the ZC99 platform. ZC99 does not knowingly use third-party advertising cookies to serve targeted advertisements based on your gaming behaviour.
Subject to applicable data protection law and the constraints of our regulatory obligations (including AML and licensing record-keeping requirements), ZC99 recognises the following rights of data subjects in respect of their personal data:
You have the right to request a copy of the personal data ZC99 holds about you, along with information about how it is processed.
You have the right to request correction of inaccurate personal data held about you, or to complete incomplete data.
You may request deletion of your personal data where it is no longer necessary for its original purpose and no overriding legal obligation requires retention.
You may request that processing of your data be restricted in certain circumstances, such as where you contest the accuracy of the data or object to its processing.
Where processing is based on consent or contract and carried out by automated means, you may request transfer of your data in a structured, machine-readable format.
You have the right to object to processing based on legitimate interests, including profiling for direct marketing purposes. You may withdraw marketing consent at any time.
To exercise any of the above rights, please contact ZC99 using the details provided in Section 16 of this Policy. Requests will be acknowledged within 5 business days and processed within 30 calendar days, subject to identity verification and any applicable regulatory constraints.
Limitations on Erasure: ZC99's AML and licensing obligations may require the retention of certain personal data (particularly KYC documentation and financial transaction records) for defined statutory periods regardless of an erasure request. In such cases, ZC99 will inform you of the applicable retention obligation and restrict further processing of the data pending the expiry of the mandatory retention period.
ZC99 implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:
Notwithstanding the above measures, no internet-based platform can guarantee absolute security of data transmission or storage. ZC99 cannot warrant that unauthorised access, hacking, data loss or other breaches will never occur. In the event of a personal data breach affecting your rights and freedoms, ZC99 will notify you and relevant supervisory authorities in accordance with applicable data protection law.
User Responsibility: You are responsible for maintaining the security of your Account credentials. ZC99 will never ask you to provide your full password in any support communication. If you suspect your Account has been accessed without your authorisation, contact ZC99 support immediately and change your password.
The ZC99 platform is exclusively intended for adults aged 18 years and above, or the higher minimum age required by the operator's license jurisdiction where that exceeds 18. ZC99 does not knowingly collect personal data from individuals under the applicable minimum age.
ZC99 employs age verification procedures as part of its KYC process to confirm that Account Holders meet the minimum age requirement. If ZC99 becomes aware that personal data has been collected from a minor, it will take prompt steps to delete that data and close the associated Account. The provision of false age information by a User is a material breach of the Terms & Conditions.
ZC99 reserves the right to update, amend or replace this Privacy Policy at any time to reflect changes in the law, our data practices, or the Services we offer. Material changes will be communicated to registered Users via email notification or a prominent on-platform notice prior to the changes taking effect.
The effective date of the current version of this Policy is displayed at the top of this page. The most current version of the Privacy Policy will always be accessible at https://zc99.cam/privacy-policy. Your continued use of the platform following the publication of an updated Policy constitutes your acknowledgement of the changes and your agreement to the revised terms where consent is not required as the applicable legal basis.
For all privacy-related enquiries, including data subject access requests, rectification and erasure requests, objections to processing, complaints regarding data handling practices, or any other question arising from this Privacy Policy, please contact the ZC99 data protection team using the details below:
Email: [email protected]
(Plain text display only — please use the on-platform contact form or live chat to submit formal data subject requests)
Subject Line for Data Requests: Please include "Data Subject Request — [Your Request Type]" in the subject line of your enquiry to ensure it is directed to the appropriate team.
Response Timeframe: ZC99 will acknowledge receipt of your request within 5 business days and complete processing within 30 calendar days, subject to identity verification requirements.
Languages: Privacy enquiries are handled primarily in English. Urdu-language support may be available on request.
All data transmitted between your device and the ZC99 platform is protected by SSL/TLS encryption. Your personal and financial information is never transmitted in plain text.
ZC99 does not sell, rent or trade your personal data to third parties for their own marketing or commercial purposes. Your data is used only as described in this Policy.
Access, rectification, erasure, portability and objection rights are all available to ZC99 Users. Requests are processed within 30 calendar days of verification.
KYC and AML data is handled in strict compliance with applicable licensing requirements. Record retention periods are determined by regulatory obligation, not Platform convenience.
Strictly necessary cookies keep the platform running. Optional analytics cookies can be managed through your browser settings. ZC99 does not serve third-party advertising cookies based on gaming behaviour.
Promotional communications are sent only to Users who have actively opted in. You may withdraw consent to marketing at any time via your Account settings or by contacting support.
If you have questions about how ZC99 handles your data, or want to know more about the platform before you register, our FAQ page and About Us section have everything you need.