ZS99 Privacy Policy

This Privacy Policy ("Policy") describes how ZS99 ("we", "us", "our", "the Platform") collects, processes, stores, shares and protects personal data provided by or collected from users ("you", "your") of the ZS99 platform at zs99.cam, including its associated interfaces and services.

ZS99 is an English-language online sports betting and casino platform serving users in Pakistan and other eligible markets. We are committed to handling personal data with care, transparency and proportionality in accordance with applicable data protection principles.

By registering an account, accessing the Platform or using any of its services, you acknowledge that you have read this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

For the purposes of this Policy, the following terms have the meanings set out below:

• "Personal Data" means any information that identifies or could identify a natural person, directly or indirectly, including name, email address, phone number, financial details, IP address and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration and deletion.
• "Data Controller" means ZS99, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of ZS99, under instruction and subject to confidentiality obligations.
• "KYC" means Know Your Customer — identity and address verification procedures required before withdrawals can be processed.
• "Cookie" means a small data file stored on your device by the Platform to maintain session state and collect usage information.
• "Legitimate Interests" means a lawful basis for processing Personal Data where ZS99 has a genuine and proportionate business reason that does not override your fundamental rights.

ZS99 collects Personal Data through the following categories and sources:

ZS99 does not collect sensitive personal data beyond what is strictly required for KYC and responsible gambling compliance. We do not request biometric data, health records or political affiliation.

ZS99 processes your Personal Data under one or more of the following lawful bases:

• Contractual Necessity: Processing required to fulfil our contract with you — including account creation, bet settlement, payment processing and withdrawal handling;
• Legal Obligation: Processing required to comply with legal and regulatory requirements, including KYC identity verification, anti-money laundering (AML) obligations and responsible gambling duties;
• Legitimate Interests: Processing that serves ZS99's genuine business interests — including fraud prevention, security monitoring, service improvement and usage analytics — provided these interests are not overridden by your fundamental rights;
• Consent: Where you have expressly agreed to certain processing activities, such as receiving promotional communications from ZS99. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

ZS99 uses your Personal Data for the following purposes:

• Account Management: Creating, maintaining and securing your ZS99 account, including password resets and login verification;
• KYC & Age Verification: Confirming your identity, age (18+ minimum, or higher as required by jurisdiction) and eligibility before allowing withdrawals or responding to responsible gambling requests;
• Payment Processing: Facilitating deposits and withdrawals in PKR via the payment methods available in the cashier — including references to Easypaisa, JazzCash, Raast, and bank transfers. These providers process only the data necessary to complete your transaction;
• Fraud Prevention & AML Monitoring: Detecting and investigating suspicious activity, unusual transaction patterns and potential financial crimes in accordance with applicable AML obligations;
• Responsible Gambling Monitoring: Tracking usage patterns to identify potential problem gambling indicators and to administer deposit limits, loss limits, cool-off periods and self-exclusion requests;
• Customer Support: Responding to your enquiries, resolving disputes and processing complaints;
• Service Improvement: Analysing aggregated and anonymised usage data to improve Platform performance, design and product offerings;
• Regulatory Compliance: Fulfilling reporting obligations to the authorities in the jurisdiction(s) in which ZS99 holds its operating licence;
• Marketing Communications: Sending promotional emails or in-Platform notifications where you have consented to receive them. You may unsubscribe at any time.

ZS99 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. Data is shared only in the following circumstances:

• Identity Verification Providers: Third-party KYC and AML service providers engaged to verify identity documents and assess risk profiles. These providers operate under strict confidentiality agreements;
• Payment Processors: Financial intermediaries and payment technology providers that facilitate deposit and withdrawal transactions. Data shared is limited to what is necessary for each transaction;
• Fraud & Security Partners: Specialist fraud-detection platforms that analyse transaction patterns on ZS99's behalf. Data is shared under data processing agreements that restrict onward use;
• Game & Software Providers: Where game studios require session data to operate their titles on the ZS99 Platform, data sharing is governed by contractual obligations between ZS99 and each provider;
• Regulatory & Law Enforcement Authorities: ZS99 will disclose Personal Data to competent authorities when required to do so by applicable law, court order or official regulatory request;
• Corporate Transactions: In the event of a merger, acquisition or sale of substantially all assets, Personal Data held by ZS99 may be transferred to the acquiring entity, subject to equivalent data protection obligations.

ZS99 operates across multiple jurisdictions and may transfer Personal Data to countries outside your country of residence, including for processing by service providers located in those countries. Where such transfers occur, ZS99 implements appropriate safeguards, which may include:

• Standard contractual clauses approved by the relevant data protection authority;
• Adequacy decisions recognising equivalent levels of data protection in the destination country;
• Binding corporate rules where applicable to intra-group transfers.

ZS99 does not transfer your Personal Data to countries that do not maintain adequate data protection standards without first implementing the safeguards described above. By using the Platform, you acknowledge that your data may be processed in jurisdictions other than Pakistan.

ZS99 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account and Registration Data: Retained for the duration of your account and for a minimum period following account closure as required by AML and regulatory obligations in the applicable jurisdiction (typically 5–7 years);
• Transaction and Financial Records: Retained for the minimum period required under applicable financial crime and AML regulations;
• KYC Documents: Retained for the period required by the applicable licence jurisdiction's compliance rules following account closure;
• Self-Exclusion Records: Retained for the duration of the exclusion period and for a period thereafter to prevent re-registration during the exclusion window;
• Technical and Usage Data: Generally retained for up to 24 months in identifiable form, after which data may be anonymised and retained for analytics purposes indefinitely.

ZS99 uses cookies and similar tracking technologies (including local storage and session identifiers) to operate the Platform and improve your experience. Cookies are small text files stored on your device when you access the Platform.

The categories of cookies ZS99 uses include:

• Strictly Necessary Cookies: Required for the Platform to function — including session management, login state persistence and security tokens. These cannot be disabled without impairing core functionality;
• Analytical Cookies: Used to understand how users interact with the Platform, which pages are most visited and where technical issues arise. Data is aggregated and not used to identify individual users;
• Functional Cookies: Store preferences such as language, display settings and recently viewed markets to improve session continuity;
• Performance Monitoring Cookies: Measure Platform response times and identify performance bottlenecks to support ongoing technical improvements.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality, including session persistence and personalisation features. ZS99 does not use third-party advertising cookies.

ZS99 implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and ZS99 servers;
• Encrypted storage for sensitive data including KYC documents and financial records;
• Role-based access controls restricting internal access to Personal Data on a need-to-know basis;
• Two-factor authentication options for Account access;
• Regular security assessments, penetration testing and vulnerability monitoring;
• Staff training on data protection obligations and incident response procedures.

While ZS99 takes reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own Account credentials. If you believe your Account has been compromised, please contact ZS99 support immediately.

Subject to the data protection law applicable in ZS99's operating jurisdiction and any overriding legal obligations, you have the following rights in respect of your Personal Data:

To exercise any of the rights above, please contact ZS99 via the details in the Contact section of this Policy. ZS99 may need to verify your identity before processing a request. ZS99 will respond within the timeframe required under the applicable data protection framework.

ZS99 is strictly an adults-only platform. Persons under the age of 18 — or the higher minimum age required by the applicable licence jurisdiction — are prohibited from registering or using the Platform in any capacity.

ZS99 does not knowingly collect Personal Data from minors. If ZS99 becomes aware that a minor has registered and provided Personal Data, the Account will be immediately suspended, all associated data will be deleted or securely returned, and any funds deposited will be returned to the originating payment method where possible.

If you have reason to believe that a minor has registered on the Platform using your details or has otherwise gained access, please contact ZS99 support immediately so that appropriate action can be taken.

The ZS99 Platform may reference or interface with third-party services, including payment processors and game studios. ZS99 is not responsible for the privacy practices of any third-party service that operates independently of the Platform.

Payment method references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are provided as familiar contextual references for Pakistani users. When you use any of these payment methods, your transaction data is also subject to the privacy policy of the respective provider. These providers do not endorse or support gambling activities and ZS99 does not claim any affiliation with them.

ZS99 recommends that you review the privacy policies of any third-party service you interact with independently of the Platform.

ZS99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, processing activities or Platform services. The revised Policy will be published on this page with an updated review date.

Where amendments are material — particularly changes that expand how your Personal Data is used or reduce your rights — ZS99 will make reasonable efforts to notify active users through in-Platform notifications or via the registered email address on your Account before the changes take effect.

For any questions, concerns or formal data subject rights requests relating to this Privacy Policy, please contact ZS99 through the following channel:

When submitting a data rights request, please include your registered Account email address and a description of the request. ZS99 may need to verify your identity before processing the request to prevent unauthorised disclosure of Personal Data.

ZS99 aims to acknowledge all data requests promptly and to respond fully within the timeframe required under the applicable data protection framework. Complex or voluminous requests may require additional time, and ZS99 will notify you of any extension within the initial acknowledgement.

For responsible gambling concerns, including self-exclusion or account closure requests, please refer to ZS99's Responsible Gambling page or contact support directly.