zs99 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how zs99 ("zs99," "we," "us," or "our"), operating the platform at https://zs99.biz, collects, uses, stores, shares, and protects personal data relating to users of the zs99 platform ("you" or "User").

By registering an Account or continuing to use the zs99 Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform immediately.

This Policy forms part of the overall agreement between you and zs99 and should be read alongside the Terms & Conditions and the Responsible Gaming Policy.

2. Data Controller

zs99 is the data controller responsible for personal data collected through the Platform. For all data-related enquiries, you may contact us at the details provided in Section 16 of this Policy. We are committed to processing your data lawfully, fairly, and transparently.

3. Data We Collect

zs99 collects the following categories of personal data:

• Identity Data: Full name, date of birth, username, copies of government-issued identity documents (CNIC, passport) submitted during KYC verification.
• Contact Data: Email address, mobile phone number, city/region of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi).
• Financial Data: Payment method identifiers (JazzCash account numbers, Easypaisa wallet references, bank account details for HBL, UBL, Meezan Bank, Bank Alfalah transfers), transaction history, deposit and withdrawal records denominated in PKR.
• Account Data: Username, password hash, account preferences, responsible gaming settings (deposit limits, self-exclusion status), promotional opt-in status.
• Transaction Data: Details of all Wagers placed, game sessions participated in, betting history, winnings credited, and bonus activity on the zs99 Platform.
• Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, time zone, and session duration.
• Usage Data: Pages visited on the Platform, search queries, game titles accessed, features used, click-stream data, and referral source.
• Communications Data: Records of support interactions via live chat or email, including the content of communications and resolution outcomes.

4. How We Collect Your Data

zs99 collects personal data through the following means:

• Direct collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically as you interact with the Platform, via server logs, session tracking, and cookies (see Section 8).
• Third-party sources: Identity verification and fraud-prevention service providers; payment processors including JazzCash, Easypaisa, and banking partners; analytics providers operating under data processing agreements with zs99.

5. Legal Basis for Processing

zs99 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to create and manage your Account, execute Wagers, process payments, and deliver the services you have requested.
• Legal obligation: Processing required to comply with applicable anti-money-laundering (AML) obligations, Know Your Customer (KYC) requirements, age verification mandates, and financial record-keeping obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, abuse detection, and improving the Platform — where such interests do not override your fundamental rights.
• Consent: Processing for marketing communications, promotional offers, and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

6. How We Use Your Data

zs99 uses your personal data for the following purposes:

• Creating, maintaining, and securing your zs99 Account.
• Processing deposits and withdrawals in PKR via JazzCash, Easypaisa, bank transfer, USDT TRC20, Visa, and Mastercard.
• Verifying your identity and age (18+) in compliance with KYC requirements.
• Settling Wagers, crediting winnings, and managing Bonus Funds.
• Detecting and preventing fraud, money laundering, cheating, and abuse of the Platform.
• Providing and improving customer support in English, including responses relevant to Pakistani players.
• Monitoring compliance with responsible gaming obligations, including enforcing self-exclusion and deposit limit settings.
• Sending transactional notifications (account activity, withdrawal confirmations, login alerts).
• Sending promotional communications where you have opted in — you may opt out at any time.
• Conducting statistical analysis to improve Platform performance, game offerings, and user experience.
• Complying with applicable regulatory, legal, or governmental requirements.

7. Data Sharing & Disclosure

zs99 does not sell your personal data to third parties. We may share your data with the following categories of recipients, under appropriate contractual protections:

• Payment processors: JazzCash, Easypaisa, banking partners (HBL, UBL, Meezan Bank, Bank Alfalah), card networks (Visa, Mastercard), and cryptocurrency processors — solely to execute payment instructions.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify identity documents and screen against sanctions lists.
• Game software providers: Game studios and platform providers that supply games available in the zs99 lobby, who may receive anonymised session data for game operation and fairness auditing.
• Technology service providers: Cloud hosting, CDN, cybersecurity, and analytics partners engaged under data processing agreements that prohibit independent use of your data.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction — including where disclosure is necessary to prevent or report suspected financial crime.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets of zs99, your data may be transferred as part of that transaction, subject to equivalent privacy protections.

All third parties with whom zs99 shares personal data are contractually required to process that data only as instructed by zs99 and in accordance with applicable data protection standards.

8. Cookies & Tracking Technologies

zs99 uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device that allow us to recognise your browser across sessions.

We use the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function — including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming configurations within your zs99 Account.
• Analytical cookies: Collect aggregated, anonymised data about how users interact with the Platform to help us improve performance and content relevance. Require your consent.
• Marketing cookies: Used to deliver relevant promotional content and measure campaign effectiveness. Require your consent and may be withdrawn at any time via your browser settings.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality. zs99 does not respond to "Do Not Track" browser signals at this time.

9. Data Retention

9.1 zs99 retains your personal data for as long as your Account remains active and for a period of five (5) years following Account closure, unless a longer retention period is required by applicable law (for example, financial record-keeping obligations applicable to payment transactions).

9.2 KYC and AML-related records (identity documents, transaction records) are retained for a minimum of five (5) years from the date of the transaction or Account closure, whichever is later, in accordance with anti-money-laundering requirements.

9.3 After the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

10. Data Security

zs99 implements technical and organisational security measures appropriate to the sensitivity of the personal data we hold, including:

• SSL/TLS encryption on all data transmitted between your device and the zs99 Platform.
• Passwords stored as salted cryptographic hashes — never in plain text.
• Role-based access controls limiting staff access to personal data on a need-to-know basis.
• Two-factor authentication available for all zs99 Accounts.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures for detecting, reporting, and addressing personal data breaches.

No data transmission over the internet is completely secure. While zs99 takes all reasonable precautions, we cannot guarantee absolute security. You should use a strong, unique password for your zs99 Account and enable two-factor authentication.

11. Your Data Rights

Subject to applicable law, you have the following rights in relation to your personal data held by zs99:

• Right of Access: Request a copy of the personal data zs99 holds about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data, subject to legal retention obligations.
• Right to Restrict Processing: Request that zs99 limit processing of your data in certain circumstances.
• Right to Data Portability: Request a structured, machine-readable copy of personal data you have provided to zs99.
• Right to Object: Object to processing based on legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact zs99 at [email protected]. We will respond within 30 days. We may require identity verification before processing your request.

12. Children's Privacy

The zs99 Platform is strictly for users aged 18 years and over. We do not knowingly collect personal data from persons under the age of 18. If 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.

Parents and guardians who believe a minor has accessed the zs99 Platform should contact us immediately at [email protected].

13. International Data Transfers

As an online platform serving Pakistani players, zs99 may transfer your personal data to servers and service providers located outside Pakistan. Where such transfers occur, zs99 ensures that appropriate safeguards are in place — including contractual data processing agreements — to protect your personal data to a standard equivalent to that described in this Policy.

14. Third-Party Links

The zs99 Platform does not include links to third-party websites as a general rule. Where any third-party content is accessible via the Platform (such as game studios embedded within the lobby), those parties operate under their own privacy policies. zs99 is not responsible for the privacy practices of third-party game studios or payment providers beyond the data processing agreements we maintain with them.

15. Policy Updates

zs99 may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. Material changes will be communicated to registered users via the email address on file or via a prominent notice on the Platform. The "Last Updated" date at the top of this page reflects the most recent revision.

Your continued use of the zs99 Platform following the effective date of any update constitutes acceptance of the revised Policy. We encourage you to review this page periodically.

16. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by zs99, please contact us:

• Email: [email protected]
• Live Chat: Available 24/7 from within your logged-in zs99 Account
• Response Time: We aim to respond to all privacy-related queries within 30 days

For responsible gaming concerns, please visit our Responsible Gaming page for dedicated tools and support resources.