Privacy Policy

Introduction

This Privacy Policy (hereinafter "the Policy") sets out the basis on which zs77 (hereinafter "zs77", "we", "us" or "our"), operating the website at https://zs77.cam, collects, processes, stores and discloses personal data relating to individuals who access or use the platform (hereinafter "users", "you" or "your").

This Policy is issued in compliance with applicable data protection legislation and forms part of the overall contractual relationship between you and zs77, alongside our Terms & Conditions and Responsible Gambling policy, each of which is incorporated herein by reference.

By accessing the zs77 platform, registering an account or otherwise providing personal data to us, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you should not access or use the platform.

Definitions

For the purposes of this Policy, the following terms carry the meanings assigned below:

• "Personal Data" — any information relating to an identified or identifiable natural person. This includes name, email address, IP address, device identifiers, financial details and any other data that can, directly or indirectly, identify an individual.
• "Processing" — any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. zs77 acts as the Data Controller for personal data collected through this platform.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, subject to binding contractual obligations.
• "KYC Data" — identity and address verification documentation provided by users as part of the Know Your Customer compliance process, including government-issued identification, proof of address and source-of-funds evidence.
• "Cookies" — small text files placed on your device by the platform to enable functional, analytical and (where consented to) personalisation purposes.
• "Sensitive Personal Data" — categories of personal data that warrant heightened protection, including financial information, government identification numbers and data relating to health or mental wellbeing (relevant in a responsible gambling context).
• "Supervisory Authority" — the relevant regulatory body responsible for overseeing data protection compliance in the applicable jurisdiction.

Data Controller

zs77, operating at https://zs77.cam, is the Data Controller in respect of personal data collected through this platform. The Data Controller is responsible for determining the purposes and means of processing and for ensuring that all processing activities comply with applicable data protection obligations.

For any data protection enquiry, subject access request or complaint, please contact us at:

We aim to acknowledge all data protection requests within five (5) business days and to respond substantively within thirty (30) calendar days of receipt, subject to the complexity of the request.

Personal Data We Collect

4.1 Registration Data

When you register an account on zs77, we collect the personal data necessary to create and manage your account, including:

• Full legal name;
• Date of birth (to verify age eligibility);
• Email address;
• Residential address (including city and postcode);
• Username and password (password stored in hashed form only);
• Mobile telephone number (where provided).

4.2 KYC & Verification Data

To comply with applicable anti-money laundering (AML) and Know Your Customer (KYC) obligations, we may collect:

• Copies of government-issued photo identification (CNIC, passport or driving licence);
• Proof of residential address (utility bill, bank statement or equivalent, dated within 3 months);
• Source-of-funds documentation (bank statements, payslips or equivalent);
• Selfie or live verification image for identity confirmation where required.

4.3 Financial Data

We collect transaction data related to deposits and withdrawal requests, including payment method identifiers (masked card numbers, mobile wallet references, bank account details and cryptocurrency wallet addresses where applicable). Full financial credentials such as full card numbers or PINs are never stored on zs77 infrastructure — these are handled directly by our payment processing partners.

References to payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are provided as contextual references to familiar Pakistani payment rails. The availability of any specific payment method, and the data it collects, is governed by the relevant provider's own terms and privacy policies. These providers do not endorse or affiliate themselves with gambling operations on zs77.

4.4 Usage & Technical Data

We automatically collect certain technical and usage data when you access the platform, including:

• IP address and approximate geolocation;
• Device type, operating system and browser version;
• Pages visited, time spent, clickstream data;
• Session start and end times;
• Referring website or source URL;
• Error logs and diagnostic data.

4.5 Communications Data

Where you contact us via email, live chat or support ticket, we retain a record of that communication, including the content of messages, timestamps and your contact details, for the purpose of resolving your query and maintaining an audit trail.

4.6 Responsible Gambling Data

Where you voluntarily use responsible gambling tools — such as deposit limits, self-exclusion or cooling-off periods — we record the settings you apply and the dates of any changes. This data is treated as sensitive personal data and is used solely to enforce the restrictions you have requested.

How We Process Your Data

The table below summarises the primary purposes for which zs77 processes personal data:

Where processing is based on legitimate interests, we have assessed that those interests do not override your fundamental rights and freedoms.

Legal Basis for Processing

We rely on the following legal bases to process your personal data:

• Contract Performance: Processing necessary to fulfil our obligations under the account registration agreement and to provide the services you have requested.
• Legal Obligation: Processing required to comply with applicable laws, including AML obligations, KYC requirements, tax reporting and regulatory record-keeping mandates.
• Legitimate Interests: Processing for purposes such as platform security, fraud detection, internal analytics and service improvement, where we have assessed that our interests are proportionate and do not override your rights.
• Consent: Where we rely on your consent (for example, for optional marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing. Withdrawal of consent does not affect processing carried out on other legal bases.
• Vital Interests: Processing necessary to protect the vital interests of a data subject, which may arise in a responsible gambling context where there is a safeguarding concern.

Data Sharing & Third Parties

7.1 Service Providers

We share personal data with carefully selected third-party service providers who assist in operating the zs77 platform. These include payment processors, identity verification providers, cloud hosting infrastructure, analytics services and customer support platforms. All such providers are bound by contractual data processing agreements that prohibit them from using your data for any purpose other than the specific services they provide to us.

7.2 Regulatory & Law Enforcement Disclosure

We may disclose personal data to competent regulatory authorities, law enforcement agencies or other public bodies where required to do so by applicable law, a valid court order or to prevent, detect or investigate fraud, money laundering or other unlawful activity. Such disclosures are made only to the extent strictly necessary and in compliance with applicable legal requirements.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of zs77's assets, personal data held by us may be transferred to the acquiring entity. Where required by applicable law, you will be notified of any such transfer and any material change to the terms of this Policy that may result.

7.4 No Sale of Personal Data

zs77 does not sell, rent, trade or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. Any sharing of data is strictly limited to the purposes described in this Policy.

Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They allow the site to remember information about your visit — such as your preferred language, login status or session preferences — and to collect usage analytics.

8.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without impairing platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gambling limits you have set.
• Analytical Cookies: Used to collect aggregated, anonymised data about how users interact with the platform. This information helps us improve performance, identify errors and understand user journeys.
• Preference Cookies: Where consented to, used to personalise content and to present relevant promotional information based on your activity on the platform.

8.3 Managing Cookie Preferences

You may manage cookie settings through your browser preferences. Most modern browsers allow you to block, restrict or delete cookies. Please note that disabling cookies may affect the functionality of the zs77 platform. Instructions for managing cookies are available in your browser's help documentation.

Data Retention

We retain personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. General retention periods are as follows:

• Account and Registration Data: Retained for the duration of your active account, plus a minimum of five (5) years after account closure to satisfy AML and regulatory record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of the last transaction or account closure, whichever is later, in compliance with anti-money laundering obligations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Communications Data: Retained for up to three (3) years from the date of the last communication, unless retention is required for an ongoing dispute or regulatory enquiry.
• Responsible Gambling Records: Retained for the duration of any active restriction plus five (5) years after its expiry, to enable enforcement of historical self-exclusion records.
• Usage and Technical Data: Anonymised or deleted within twelve (12) months of collection, except where required for security investigations.

Upon expiry of the applicable retention period, personal data is securely deleted, destroyed or irreversibly anonymised so that it can no longer be attributed to an identifiable individual.

Security Measures

zs77 implements a range of technical and organisational security measures to protect personal data against unauthorised access, loss, alteration or destruction. These measures include:

• TLS/SSL encryption for all data in transit between your device and our servers;
• Hashed and salted storage of passwords — we never store passwords in plain text;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Audit logging of access to sensitive personal data and administrative actions;
• Regular security assessments and vulnerability reviews of platform infrastructure;
• Two-factor authentication available for user accounts and enforced for administrative access;
• Data processor agreements imposing equivalent security standards on all third-party service providers.

While we employ robust security measures, no online platform can guarantee absolute security against all threats. You are responsible for maintaining the security of your account credentials and for notifying us promptly of any suspected unauthorised access.

Your Data Rights

Subject to applicable law and certain conditions, you have the following rights in relation to your personal data held by zs77:

International Data Transfers

The operation of the zs77 platform may involve the transfer of personal data to, or processing by, entities located in jurisdictions outside of your country of residence. Where such transfers occur, zs77 ensures that appropriate safeguards are in place to protect the personal data transferred, which may include:

• Standard contractual clauses approved by the relevant supervisory authority;
• Binding corporate rules where applicable;
• Transfers to jurisdictions recognised as providing an adequate level of data protection;
• Other transfer mechanisms permitted under applicable data protection law.

You may request further information about the specific safeguards applied to international transfers by contacting our data protection contact at [email protected].

Protection of Minors

The zs77 platform is strictly for use by adults aged 18 years or older — or the higher minimum age required by the applicable operator licence jurisdiction or your country of residence. We do not knowingly collect personal data from individuals under the age of 18.

We conduct age verification checks as part of the KYC process to enforce this restriction. Where we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the platform, please contact us immediately at [email protected].

Parents and guardians are encouraged to use parental controls and internet filtering tools to prevent minors from accessing gambling platforms. Please visit our Responsible Gambling page for further guidance.

Amendments to This Policy

zs77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users via email or an in-account notification.

Your continued use of the zs77 platform following the publication of a revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to remain informed of how your personal data is being handled. The current version of this Policy is always accessible at https://zs77.cam/privacy-policy.

Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by zs77, please contact us through the following channels:

If you are not satisfied with our response to a privacy complaint, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.