Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is published by zs111 (hereinafter referred to as "we", "us", "our" or "the Platform") and applies to all personal data collected from users ("you", "your" or "User") who access, register on, or otherwise interact with the website located at zs111.cam.

zs111 is an online casino and sports betting information platform serving users in Pakistan and other permitted jurisdictions. We are committed to protecting your personal information and being fully transparent about how we handle it. This Policy sets out in clear, plain terms what data we collect, the purposes for which it is used, the legal basis for processing, and your rights in relation to that data.

This Policy should be read alongside the Terms & Conditions governing use of the Platform and the Responsible Gambling Policy. By using the Platform, you agree to the data practices described in this Policy. If you do not agree, please discontinue use of the Platform immediately.

2. Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person — i.e., information that can be used, directly or indirectly, to identify you.
• "Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, transmission, deletion or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, the Operator of zs111.
• "Data Processor" means any third party that processes personal data on behalf of the Data Controller, pursuant to a binding data processing agreement.
• "KYC" means Know Your Customer — the identity verification process required by the Operator prior to processing withdrawals or as otherwise specified.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences and usage data.
• "AML" means Anti-Money Laundering — the legal framework and internal controls applied by the Operator to detect, prevent and report suspicious financial activity.
• "User" means any individual who accesses or registers an account on the Platform, including registered players and casual visitors.

3. Personal Data We Collect

We collect personal data across several categories, depending on your level of interaction with the Platform:

3.1 Registration & Account Data

• Full legal name
• Date of birth (for age verification)
• Email address
• Phone number (where provided)
• Username and encrypted password
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents: Pakistani CNIC, passport or other accepted identification
• Proof of address documents (where required)
• Selfie or liveness verification image or video
• Source of funds documentation (where required by AML procedures)

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method identifiers (wallet IDs, masked card numbers, bank account references — not full card numbers)
• Transaction amounts in PKR or applicable currency
• Transaction timestamps and status records

3.4 Gameplay & Betting Activity Data

• Game sessions, bet records, wager amounts and outcomes
• Sports markets accessed, cricket betting activity, casino game history
• Bonus and promotion usage records
• Responsible gambling settings and limit configurations

3.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, browser type and version
• Pages visited, session duration and navigation patterns
• Referral source and UTM parameters (where applicable)

3.6 Communications Data

• Records of support interactions via email or live chat
• Feedback, complaint and dispute correspondence
• Marketing preference records and opt-in/opt-out history

4. How Your Data Is Collected

We collect your personal data through the following means:

• Direct collection: Information you provide voluntarily when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account profile.
• Automatic collection: Technical data collected automatically when you access the Platform, including cookies, log files, device fingerprinting data and analytics tracking.
• Third-party sources: Verification data received from licensed KYC/identity verification providers where you have consented to that verification; fraud and AML screening data from licensed compliance partners.
• Payment processing: Transaction-level data received from payment processors when you initiate a deposit or withdrawal through the cashier, including confirmation references and transaction status updates.

5. Data Processing & Legal Basis

We process your personal data for the following purposes, each of which is supported by an appropriate legal basis:

We will not process your personal data for purposes that are incompatible with those stated above without first obtaining your explicit consent or establishing an alternative legal basis.

6. Data Sharing & Disclosure

zs111 does not sell, rent or trade your personal data. We may share data with the following categories of recipients under strictly defined conditions:

6.1 Licensed Service Providers

We engage third-party service providers who process personal data on our behalf to support Platform operations. These include:

• KYC and identity verification providers (for CNIC/passport validation and liveness checks)
• Payment processors and gateway operators
• Fraud detection and AML screening services
• Cloud hosting and data storage providers
• Customer support platform operators
• Analytics service providers (aggregated, non-personally-identifiable data only)

All service providers are bound by data processing agreements that prohibit them from using your data for any purpose beyond the specific services they are engaged to provide.

6.2 Regulatory and Legal Disclosures

We may disclose personal data to competent regulatory authorities, law enforcement agencies or courts where we are legally required or compelled to do so — for example, in connection with AML investigations, fraud inquiries, court orders or regulatory inspections. Such disclosures are made only to the minimum extent required by law.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets or restructuring involving the Operator, personal data held by zs111 may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections. Users will be notified of any material change to data controller identity.

7. International Data Transfers

Given that zs111 operates as an international platform, your personal data may be processed in countries outside Pakistan. In some of these jurisdictions, data protection standards may differ from those you may be familiar with.

Where personal data is transferred internationally, we take steps to ensure that appropriate safeguards are in place to protect the security and integrity of that data. These safeguards may include:

• Standard contractual clauses approved by applicable data protection authorities
• Binding corporate rules where relevant
• Data processing agreements that impose equivalent privacy obligations on the recipient

By using the Platform, you acknowledge that your personal data may be processed internationally and consent to those transfers subject to the safeguards described above.

8. Cookies & Tracking Technologies

zs111 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device when you visit the Platform. Cookies allow us to recognise your device on return visits, maintain your session, and understand how you interact with the Platform.

8.1 Types of Cookies We Use

8.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies and receive a warning before a cookie is set. Please note that disabling certain cookies may affect Platform functionality. Refer to your browser's help documentation for specific cookie management instructions.

We do not use advertising cookies or cross-site tracking technologies to build advertising profiles based on your browsing activity outside of zs111.

9. Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes described in this Policy, to comply with legal and regulatory obligations, and to resolve disputes and enforce our agreements.

• Account Data: Retained for the duration of your active account relationship and for a minimum of five (5) years following account closure, to comply with AML and regulatory record-keeping obligations.
• KYC Documents: Retained in accordance with applicable AML regulatory requirements — typically five (5) years from the end of the business relationship, unless a longer period is required by law.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with financial record-keeping requirements.
• Support Correspondence: Retained for a minimum of two (2) years from the date of last interaction, or for the duration of any ongoing dispute resolution process.
• Technical Logs: Typically retained for up to twelve (12) months for security and fraud analysis purposes.
• Marketing Preferences: Retained until you withdraw consent or close your account, whichever occurs first.

When data is no longer required for any of the above purposes, it is securely deleted or anonymised in a manner that prevents re-identification.

10. Your Data Rights

Subject to applicable data protection law, you have the following rights in relation to your personal data held by zs111. These rights may be subject to certain limitations where our legal obligations require us to retain data or where exercising a right would adversely affect third parties.

To exercise any of the above rights, please contact our support team at [email protected]. We will respond to all verified data rights requests within 30 days of receipt. We may need to verify your identity before acting on any request to ensure your data is not disclosed to an unauthorised party.

11. Security Measures

zs111 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration or destruction. These measures include:

• Transport encryption: All data transmitted between your browser and the Platform is protected by industry-standard SSL/TLS encryption. Look for the padlock icon in your browser's address bar before logging in.
• Data encryption at rest: Sensitive data fields including KYC documents and financial records are stored using encryption protocols that prevent unauthorised access even in the event of a storage breach.
• Access controls: Access to personal data within the organisation is restricted to authorised personnel with a specific operational need. Access rights are reviewed regularly and revoked when no longer required.
• Fraud and anomaly detection: Automated systems monitor account activity for anomalous behaviour patterns consistent with fraud, account takeover or AML risk indicators.
• Incident response: We maintain documented procedures for identifying, containing and reporting personal data security incidents in accordance with applicable regulatory requirements.

12. Minors & Age Restrictions

zs111 is strictly intended for adults aged 18 years and above — or the higher minimum age required by the operator's license jurisdiction, whichever is greater. We do not knowingly collect, store or process personal data belonging to individuals under the applicable minimum age.

If you are a parent or guardian and believe that a minor under your care has provided personal data to zs111 and registered an account, please contact us immediately at [email protected]. Upon confirmation, we will take prompt steps to delete the account and all associated personal data.

13. Pakistan-Specific Context

zs111 serves a significant user base in Pakistan — including players from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We are aware that Pakistan does not currently have a comprehensive standalone data protection law equivalent to frameworks such as the GDPR, though the Personal Data Protection Bill has been under consideration.

Regardless of the specific legislative framework applicable in Pakistan at any given time, zs111 is committed to applying data privacy principles consistent with international best practice, including purpose limitation, data minimisation, storage limitation, accuracy, integrity and confidentiality.

Pakistani users should also be aware that the Prevention of Electronic Crimes Act (PECA) 2016 and other applicable Pakistani legislation may govern certain aspects of online data handling. This Policy does not constitute legal advice under Pakistani law. If you have concerns about your data rights under Pakistani legislation, please consult a qualified legal professional.

14. Policy Amendments

We reserve the right to update or modify this Privacy Policy at any time. Material changes — such as changes to the types of data collected, the purposes for which it is used, or significant changes to your rights — will be communicated to registered Users via email notification or a prominent notice on the Platform at least fourteen (14) days prior to the changes taking effect.

Non-material changes, such as typographical corrections or clarifications that do not alter your substantive rights, may be made without prior notice. The "Effective Date" at the top of this page indicates the date on which the current version of this Policy came into force.

Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy. We recommend reviewing this page periodically to stay informed of how your data is being handled.

15. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your personal data, please contact our Privacy & Data Protection team through any of the following channels:

We aim to acknowledge all privacy-related requests within five (5) business days and to resolve them within thirty (30) days. Complex requests involving large volumes of data or requiring third-party coordination may take longer, in which case we will notify you of the extended timeline.