ZN99 Privacy Policy

This Privacy Policy ("Policy") describes how ZN99 ("ZN99", "we", "us", "our") collects, uses, stores, discloses and protects the personal information of users ("you", "User", "Player") who access or use the ZN99 online gaming platform at https://zn99.cam ("Platform").

ZN99 is an English-language online gaming information and services platform primarily directed at users based in Pakistan and other permitted jurisdictions. We are committed to handling your personal data responsibly, transparently and in compliance with applicable data protection frameworks.

This Policy should be read in conjunction with the ZN99 Terms & Conditions, which govern your overall use of the Platform. By registering for an account, depositing funds or continuing to use ZN99, you acknowledge that you have read and understood this Policy.

The following definitions apply throughout this Privacy Policy:

• Personal Data: Any information relating to an identified or identifiable natural person, including name, national identity number (CNIC), contact details, financial information, device identifiers and location data.
• Processing: Any operation performed on personal data — including collection, recording, storage, use, disclosure, erasure or destruction.
• Data Controller: The entity that determines the purposes and means of processing personal data. ZN99 acts as the Data Controller for personal data collected through the Platform.
• Data Processor: A third party that processes personal data on behalf of the Data Controller, under written instructions and contractual safeguards.
• KYC (Know Your Customer): The identity and age verification process required before a User may withdraw funds or access certain Platform features.
• Cookies: Small text files placed on a User's device by the Platform for functionality, analytics and personalisation purposes.
• Special Category Data: Particularly sensitive personal data including health information, which is processed only under limited and necessary circumstances (e.g., responsible gambling assessments).

ZN99 collects only the personal data necessary to provide, maintain and improve the Platform and its associated services. The categories of data we collect are set out in the table below:

ZN99 collects personal data through the following channels:

4.1 Directly From You

• During account registration (name, email, date of birth, password);
• When completing KYC verification (CNIC, selfie, proof of address);
• When initiating deposits or withdrawals (payment method details);
• When contacting support via email or live chat;
• When setting responsible gambling preferences or limits in your Account.

4.2 Automatically Through Platform Use

• Technical data (IP address, device information, session data) collected automatically when you access the Platform;
• Cookies and similar tracking technologies (see Section 10);
• Betting and gaming activity logs generated as you use the Service.

4.3 From Third Parties

• Identity verification service providers used to cross-check KYC documents;
• Payment processors (e.g., third-party cashier providers) confirming transaction status — note that payment provider names referenced contextually do not imply endorsement of gambling operations;
• Fraud detection and anti-money laundering (AML) screening services;
• Analytics providers supplying aggregated platform usage data.

ZN99 processes your personal data under one or more of the following lawful bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and ZN99 — including account management, payment processing, KYC verification and game delivery;
• Legal Obligation: Processing required to comply with applicable law — including anti-money laundering (AML) obligations, age verification requirements and regulatory record-keeping;
• Legitimate Interests: Processing for purposes that are in the legitimate interests of ZN99 or third parties, where these interests are not overridden by your rights — including fraud prevention, security monitoring, platform improvement and responsible gambling monitoring;
• Consent: Where you have provided explicit consent — for example, to receive marketing communications. You may withdraw consent at any time by contacting support or updating your Account preferences.

ZN99 uses personal data collected from Pakistani users and others for the following specific purposes:

6.1 Account Management and Service Delivery

We use your identity, contact and account activity data to create and manage your ZN99 account, verify your eligibility, process your bets and transactions, and deliver the games and sports betting services you have requested.

6.2 KYC Verification and Regulatory Compliance

Your identity documents (including CNIC), selfie and proof of address are used to verify your identity and age as required by the Operator's licensing obligations and applicable AML frameworks. This is a legal obligation and cannot be waived.

6.3 Payment Processing

Financial data is processed to facilitate deposits and withdrawals through the available cashier methods. ZN99 does not store full payment card details on its own servers — such data is handled by certified third-party payment processors. References to Pakistani payment channels (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are for context only and do not imply that these providers endorse or support gambling operations.

6.4 Fraud Prevention and Security

Technical data, account activity patterns and transaction history are monitored to detect and prevent fraud, money laundering, multi-accounting and other prohibited conduct. This processing is in the legitimate interests of ZN99 and its genuine users.

6.5 Responsible Gambling

Account activity data and self-declared preference settings are used to monitor gambling behaviour, enforce user-set limits, trigger responsible gambling interventions where necessary and administer self-exclusion requests. This processing may in limited circumstances involve health-related data (where voluntarily disclosed by you in a responsible gambling context), processed on the basis of substantial public interest.

6.6 Customer Support

Communications data from support tickets, live chat and email is used to address your queries, resolve complaints and improve support quality. Support interactions may be monitored for quality assurance purposes.

6.7 Marketing Communications (Consent-Based)

With your explicit consent, ZN99 may send you promotional emails or notifications regarding offers, bonuses or platform updates. You may opt out at any time via your Account settings or by contacting support. ZN99 does not sell your data to third parties for their marketing purposes.

6.8 Platform Analytics and Improvement

Aggregated and anonymised usage data is used to understand how users interact with the Platform, identify technical issues and improve the overall user experience for players across Pakistan — from Karachi to Peshawar.

ZN99 does not sell, rent or trade your personal data to any third party for commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and under appropriate contractual protections:

• KYC and Identity Verification Providers: Third-party services used to verify your identity documents, age and liveness checks;
• Payment Processors: Certified third-party cashier and payment gateway providers who process deposit and withdrawal transactions on behalf of ZN99;
• Fraud Detection and AML Services: Specialist providers used to screen transactions and accounts against sanctions lists, fraud databases and AML watchlists;
• Cloud and Infrastructure Providers: Secure hosting and data storage providers operating under strict data processing agreements;
• Customer Support Platforms: Third-party helpdesk or live chat tools used to manage support communications;
• Analytics Providers: Services providing aggregated, anonymised platform analytics — personal identifiers are not shared in this context;
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order or regulatory direction, ZN99 may be obliged to disclose personal data to competent authorities. We will notify you of any such disclosure where legally permitted to do so.

ZN99 retains personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable legal, regulatory and contractual obligations. The principal retention periods are as follows:

• Account and KYC Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, to satisfy AML and record-keeping obligations;
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of the transaction in accordance with financial record-keeping requirements;
• Communications and Support Records: Retained for up to three (3) years from the date of the communication, unless required longer for complaint resolution or legal proceedings;
• Technical and Log Data: Typically retained for up to twelve (12) months from the date of generation, subject to security investigation requirements;
• Marketing Consent Records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.

Where data is no longer required for any active purpose and no legal retention obligation applies, ZN99 will securely delete or irreversibly anonymise the data.

ZN99 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Encryption: Personal data is encrypted in transit using TLS (Transport Layer Security) and at rest using industry-standard encryption protocols;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis with role-based access controls and multi-factor authentication for internal systems;
• Pseudonymisation: Where feasible, personal data is pseudonymised to reduce risk in the event of a breach;
• Security Monitoring: Continuous monitoring of platform infrastructure for anomalous activity, intrusion attempts and vulnerabilities;
• Penetration Testing: Regular security assessments of the Platform and its underlying infrastructure;
• Staff Training: All personnel with access to personal data receive appropriate data protection and information security training.

In the event of a personal data breach that poses a risk to your rights and freedoms, ZN99 will take prompt remedial action and notify affected users and relevant authorities in accordance with applicable obligations.

ZN99 uses cookies and similar technologies (including pixels and local storage) to operate the Platform effectively, remember your preferences and analyse usage patterns. The categories of cookies used are:

10.1 Strictly Necessary Cookies

Essential for the Platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery. They cannot be disabled without impairing core Platform functionality.

10.2 Functional Cookies

Used to remember your preferences — such as language settings, responsible gambling limit settings and display preferences. Disabling these cookies may affect personalisation features.

10.3 Analytics Cookies

Used to collect aggregated, anonymised data about how users navigate the Platform — which pages are visited most, where sessions begin and end, and technical performance metrics. This data informs platform improvements. Analytics cookies do not identify individual users.

10.4 Managing Cookies

You can control non-essential cookies through your browser settings or any cookie preference centre provided on the Platform. Blocking cookies may affect your experience of certain Platform features. Most modern browsers allow you to view, delete and block cookies — refer to your browser's help documentation for instructions.

Subject to applicable law and certain limited exceptions, you have the following rights in respect of your personal data held by ZN99. To exercise any of these rights, contact us at [email protected] with a clear description of your request. We will acknowledge your request within 72 hours and respond substantively within 30 days (extendable by a further 60 days for complex requests).

ZN99 is an adults-only platform. We do not knowingly collect personal data from any person under the age of 18, or the higher minimum age required by the applicable operator licence jurisdiction. Age verification is a mandatory part of the KYC process for all users.

If ZN99 becomes aware that personal data has been collected from a minor without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. All deposits and winnings associated with such an account may be voided pending investigation.

ZN99 may process and store personal data on servers located outside Pakistan. Where personal data is transferred to countries that may not provide data protection standards equivalent to those applicable in the Operator's licensing jurisdiction, ZN99 implements appropriate safeguards to ensure that the transfer is lawful and your data remains protected.

Such safeguards may include:

• Contractual clauses incorporating recognised data protection obligations between ZN99 and the receiving entity;
• Transferring data only to certified or accredited third parties with demonstrated data protection compliance programmes;
• Technical measures such as encryption to protect data during and after transfer.

You may request further information about the specific safeguards in place for any international transfer of your personal data by contacting our support team.

ZN99 reserves the right to update, amend or replace this Privacy Policy at any time. The effective date at the top of this page will be updated whenever material changes are made. Where changes are significant, ZN99 will provide prominent notice — such as a notification on the Platform or an email to your registered address — prior to the changes taking effect.

Your continued use of the ZN99 Platform following publication of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree to the revised Policy, you must discontinue use of the Platform and may request account closure by contacting support.

We encourage you to review this Policy periodically to stay informed about how ZN99 protects your personal data.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have concerns about the way ZN99 processes your personal data, please contact us using the details below. All privacy-related correspondence is handled with strict confidentiality.

15.1 Complaints

If you are not satisfied with ZN99's response to a privacy concern, you have the right to escalate your complaint to the relevant supervisory or data protection authority in your jurisdiction, or to the Operator's licensing authority. Further details of the applicable authority are available upon written request to ZN99 support.