z111 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how z111 ("z111", "we", "us", "our") collects, uses, stores, and protects personal data relating to visitors and registered players of the website located at z111.bio and all associated gaming services, mobile interfaces, and promotional platforms operated under the z111 brand.

z111 is committed to handling personal data responsibly, transparently, and in compliance with applicable data protection laws and the requirements of its international gaming licence. By accessing z111.bio or registering a z111 account, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy should be read alongside z111's Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the z111 platform.

2 Data Controller

For the purposes of applicable data protection legislation, z111 acts as the data controller in respect of the personal data collected through z111.bio. The data controller is responsible for determining the purposes and means by which your personal data is processed.

If you have any questions about how z111 processes your personal data, or wish to exercise any of your data rights as described in Section 12 of this Policy, please contact our dedicated support team whose details are provided in Section 16.

3 Personal Data We Collect

z111 collects the following categories of personal data in connection with the operation of its gaming platform and the delivery of its services:

3.1 Identity & Registration Data

• Full legal name, date of birth, and gender;
• National identity card (CNIC) number or passport number;
• Residential address, city (e.g., Karachi, Lahore, Islamabad, Faisalabad), and postcode;
• Email address and mobile phone number;
• Username and encrypted password.

3.2 KYC & Verification Documents

• Copies of government-issued photo identification;
• Proof of address documents (utility bills, bank statements dated within 3 months);
• Payment method verification documentation (JazzCash, EasyPaisa, bank account screenshots);
• Source of funds declarations where deposit thresholds are exceeded.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, amounts, and timestamps;
• Payment method details (mobile wallet numbers, bank account references, card last four digits);
• Bonus activation, wagering history, and promotional participation records;
• PKR account balance history.

3.4 Gaming & Behavioural Data

• Game session logs, bet history, and win/loss records across all z111 products (cricket betting, slots, live casino, Teen Patti);
• Login history, session duration, and in-platform navigation patterns;
• Responsible gaming preferences, limit settings, and self-exclusion records;
• Customer support interaction history.

3.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Cookie identifiers and session tokens;
• Referring URL and on-site behaviour analytics.

4 How We Collect Your Data

z111 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 behavioural data gathered automatically through cookies, server logs, and analytics tools as you interact with z111.bio;
• Third-party sources: Identity verification agencies, payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank), fraud prevention services, and our licensing authority where required for compliance purposes.

5 How We Use Your Personal Data

z111 uses collected personal data for the following purposes:

Purpose	Data Categories Used
Account registration and management	Identity, contact, login data
KYC identity and age verification (21+)	Identity, KYC documents
Processing deposits and withdrawals in PKR	Financial, identity data
Delivering gaming services and products	Gaming, behavioural, technical data
Fraud detection and anti-money laundering compliance	All categories as necessary
Responsible gaming monitoring and support	Gaming, behavioural, identity data
Customer support and dispute resolution	Identity, transaction, gaming data
Promotional and bonus administration	Identity, financial, gaming data
Platform security and technical maintenance	Technical, device data
Regulatory reporting to licensing authority	Identity, financial, gaming data
Marketing communications (with consent)	Identity, contact, behavioural data

6 Legal Bases for Processing

z111 processes your personal data only where a valid legal basis exists under applicable data protection law. The primary legal bases on which z111 relies are:

• Contractual necessity: Processing required to fulfil z111's obligations under your account agreement, including account management, transaction processing, and KYC compliance;
• Legal obligation: Processing required to comply with z111's regulatory obligations under its gaming licence, including anti-money laundering (AML) checks, age verification, and regulatory reporting;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement where such interests are not overridden by your data rights;
• Consent: Processing for optional marketing communications and non-essential cookies, where you have provided explicit opt-in consent which may be withdrawn at any time.

7 Sharing Your Personal Data

z111 does not sell your personal data. We may share your data with the following categories of third parties strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Payment Processors

Transaction data is shared with payment service providers including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/Mastercard networks, and USDT processing partners solely to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable financial regulation.

7.2 Identity Verification Providers

During KYC processes, z111 may share identity documents and personal details with accredited third-party identity verification agencies to confirm your identity, age, and document authenticity in accordance with our licensing obligations.

7.3 Fraud & AML Screening Services

z111 uses specialist third-party services to screen transactions and account activity for indicators of fraud, money laundering, or other financial crime. Data shared for this purpose is limited to what is strictly necessary for the screening process.

7.4 Gaming Software Providers

Game session data, including bet and win records, may be shared with z111's licensed game content providers (slots, live casino, sportsbook, Teen Patti providers) to the extent necessary for game delivery, fairness auditing, and dispute resolution.

7.5 Regulatory & Legal Authorities

z111 may disclose personal data to its licensing authority, law enforcement agencies, or other competent authorities where required by law, court order, or regulatory direction. z111 will notify affected players of such disclosures where legally permitted to do so.

7.6 Professional Advisors

In limited circumstances, personal data may be shared with legal, accounting, or auditing firms engaged by z111 under strict confidentiality obligations for the purposes of professional advice or compliance audits.

8 Cookies & Tracking Technologies

z111 uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyse site usage, and deliver relevant content. The categories of cookies used on z111.bio are as follows:

• Strictly Necessary Cookies: Essential for platform functionality, session management, and security. These cannot be disabled without significantly impairing your ability to use z111;
• Performance & Analytics Cookies: Used to collect anonymised data about how visitors interact with z111.bio, helping us improve platform performance and user experience;
• Functional Cookies: Used to remember your preferences, language settings, and login state across sessions;
• Marketing Cookies: Used with your consent to deliver relevant promotional content related to z111 products and seasonal campaigns such as Eid and PSL promotions. These may be disabled at any time via your account settings or browser preferences.

You may manage or withdraw cookie consent at any time through your browser settings. Note that disabling strictly necessary cookies may prevent you from accessing certain z111 platform features.

9 Data Retention

z111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our licensing obligations. The following general retention periods apply:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, as required for AML and regulatory compliance;
• KYC documentation: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction in accordance with financial record-keeping requirements;
• Customer support records: Retained for three (3) years from the date of each interaction;
• Marketing preferences: Retained until you withdraw consent or close your account, whichever occurs first;
• Technical logs: Retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, z111 will securely delete or anonymise personal data in accordance with industry-standard data disposal procedures.

10 Data Security

z111 implements robust technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security framework includes:

• SSL/TLS encryption for all data transmitted between your device and z111.bio;
• AES-256 encryption for sensitive data stored at rest, including payment information and identity documents;
• Multi-factor authentication options for player account access;
• Role-based access controls restricting internal staff access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent third parties;
• 24/7 intrusion detection and monitoring systems;
• Incident response procedures for timely detection, containment, and notification of data breaches where required.

While z111 takes all reasonable precautions to safeguard your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your z111 login credentials and should notify z111 immediately if you suspect unauthorised access to your account.

11 International Data Transfers

z111 operates under an international gaming licence, and some of the third-party service providers with whom we share data (as described in Section 7) may process data in jurisdictions outside Pakistan. Where such transfers occur, z111 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those observed by z111;
• Transfer only to service providers operating in jurisdictions with recognised data protection frameworks;
• Data processing agreements with all third-party processors specifying the scope, purpose, and security requirements for any data processing.

12 Your Data Rights

Subject to applicable law and our regulatory obligations, you have the following rights in relation to the personal data z111 holds about you:

• Right of Access: You may request a copy of the personal data z111 holds about you at any time. z111 will provide a response within 30 days of receiving a valid request;
• Right to Rectification: If any personal data held by z111 is inaccurate or incomplete, you have the right to request correction. You may also update basic account details directly within your z111 account dashboard;
• Right to Erasure: You may request deletion of your personal data. Note that z111 may be required to retain certain data for regulatory or legal compliance purposes as described in Section 9, which may limit the scope of erasure requests;
• Right to Restriction: You may request that z111 restrict the processing of your personal data in certain circumstances, for example while a rectification request is under review;
• Right to Data Portability: You may request that z111 provide a copy of your personal data in a structured, machine-readable format for transfer to another service provider, where technically feasible;
• Right to Object: You have the right to object to processing of your data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to z111's ability to demonstrate compelling grounds;
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact z111 support via live chat or email as detailed in Section 16. z111 will verify your identity before processing any data rights request. There is no fee for submitting a data rights request.

13 Children and Minors

z111 operates a strict 21+ age policy. The z111 platform is not intended for, directed at, or accessible to anyone under the age of 21. z111 does not knowingly collect or process personal data belonging to persons under 21 years of age.

All registration attempts are subject to age verification checks during the KYC process. Where z111 discovers or has reasonable grounds to believe that an account holder is under 21 years of age, the account will be immediately suspended, all associated personal data will be securely deleted (except where retention is required by law), and any wagering activity conducted during the underage period will be voided.

If you are a parent or guardian and believe that a person under 21 has registered an account on z111, please contact our support team immediately so that the account can be investigated and closed.

14 Third-Party Services & Links

z111 may reference or integrate third-party services for payment processing, identity verification, and gaming software delivery. These third-party services operate under their own privacy policies, which z111 does not control. z111 encourages you to review the privacy policies of any third-party service providers whose services you access in connection with your z111 account.

z111 is not responsible for the privacy practices, data handling, or security measures of third-party operators, nor for any data loss or breach occurring on third-party platforms outside z111's direct control.

15 Changes to This Privacy Policy

z111 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed prominently at the top of this page.

Where changes are material, z111 will notify registered players via email to the address associated with their account, or via a prominent notice on z111.bio, at least fourteen (14) days prior to the changes taking effect. Continued use of z111 following notification of a policy amendment constitutes acceptance of the revised Privacy Policy.

If you do not agree with any changes to this Policy, you should cease using z111 and may request account closure with withdrawal of any available balance.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or z111's handling of your personal data, please get in touch with our support team through any of the following channels:

• Live Chat: Available 24/7 on z111.bio — average response time under 90 seconds
• Email: [email protected] — responses within 24 hours
• Languages: English and Urdu

z111 is committed to resolving all privacy-related enquiries fairly, promptly, and in full compliance with its licensing obligations and applicable data protection law.