Privacy Policy

This Privacy Policy ("Policy") is issued by zc111 ("the Platform", "we", "us", "our") and applies to all individuals ("User", "you", "your") who access, browse, register on, or otherwise interact with the zc111 online gaming platform at https://zc111.cam and any associated mobile-optimised versions thereof.

zc111 is an English-language online gaming platform serving the Pakistani market. In the course of providing our services — which include sports betting, live casino, slots, table games, esports, and instant game categories — we necessarily collect and process personal data. This Policy sets out the full scope of that data processing in a transparent and accessible manner.

We are committed to handling personal data in accordance with applicable data protection legislation in our operating jurisdiction. This Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform.

For the purposes of this Policy, the following terms are defined as follows:

• "Personal Data" means any information that identifies or could reasonably be used to identify a natural person, directly or indirectly — including name, email address, date of birth, phone number, payment details, device identifiers, and IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, zc111.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a contractual agreement and subject to the Controller's instructions.
• "Consent" means a freely given, specific, informed, and unambiguous indication of the User's agreement to the processing of their Personal Data for a stated purpose.
• "KYC Data" means identity verification documentation submitted by a User in fulfilment of Know Your Customer requirements, including CNIC copies, proof of address, and payment method evidence.
• "Cookies" means small text files placed on a User's device by a web server to store information about the User's browsing session or preferences.

We collect Personal Data from you in the following categories, depending on your interaction with the Platform:

3.1 Registration & Account Data

Collected when you create an Account on the Platform:

• Full legal name
• Date of birth
• Residential address (including city — such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, or Peshawar)
• Email address
• Mobile phone number
• Username and hashed password
• Preferred currency (PKR)

3.2 Identity Verification (KYC) Data

Collected when you undergo identity verification, which may be required before your first withdrawal or when triggered by compliance procedures:

• Government-issued photographic identity document (for Pakistani users, typically a Computerised National Identity Card — CNIC)
• Proof of residential address (utility bill, bank statement, or equivalent)
• Proof of payment method ownership (for example, confirmation of an Easypaisa wallet, JazzCash account, or bank account held in your registered name)
• Selfie with identity document, if requested during enhanced verification

3.3 Financial Transaction Data

• Deposit and withdrawal records including amounts in PKR, timestamps, and payment method references
• Payment method identifiers (partial account or card numbers; we do not store full card numbers)
• Transaction history and account balance records

3.4 Gameplay & Betting Activity Data

• Game sessions, bet history, wagering amounts, and win/loss records
• Bonus activation, wagering progress, and promotion participation records
• Sports betting selections, live betting activity, and esports market interactions

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser or app version
• Session timestamps, page views, and navigation paths
• Cookie identifiers and similar tracking technology data (see Section 9)

3.6 Communications Data

• Records of live chat conversations, email correspondence, and support ticket submissions
• Feedback, survey responses, and complaint records

We process your Personal Data under one or more of the following legal bases, depending on the purpose of the processing activity:

We use the Personal Data we collect for the following purposes:

• Account creation and management: Setting up, maintaining, and securing your registered Account on the Platform.
• Service delivery: Enabling you to place bets, play casino games, participate in promotions, and use all other Platform features.
• Financial processing: Facilitating PKR deposits and withdrawal requests via the payment methods referenced in the Platform's cashier.
• Identity and age verification: Confirming that you meet the 18+ minimum age requirement and that your identity matches the details you provided at registration.
• Fraud detection and security: Identifying suspicious account behaviour, detecting duplicate registrations, and protecting the integrity of the Platform.
• Anti-money laundering (AML) compliance: Monitoring transactions and account activity in accordance with the AML obligations applicable in the Platform's licensing jurisdiction.
• Responsible gambling: Enforcing deposit limits, self-exclusion requests, and other responsible gambling controls you have activated on your Account.
• Customer support: Responding to your enquiries, resolving disputes, and managing your complaint through our internal process.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the Platform's performance, content, and user experience.
• Marketing (with your consent): Sending promotional emails, bonus notifications, and personalised offers where you have opted in. You may withdraw consent at any time.
• Legal compliance: Retaining records and responding to lawful requests from regulatory or law enforcement authorities where required.

zc111 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

6.1 Operational Service Providers

We engage third-party Data Processors to assist in delivering our services. These may include:

• Payment processing providers: To facilitate PKR transactions, including references to payment infrastructure such as HBL, UBL, Meezan Bank, Bank Alfalah, Easypaisa, JazzCash, and Raast-based transfers. These references are contextual; actual processing partners are confirmed in the cashier and subject to their own privacy policies.
• Identity verification and KYC providers: To conduct automated or assisted identity checks on submitted documentation including CNIC verification.
• Game software suppliers: To deliver game content; these providers may receive session and gameplay data necessary for game functionality and fairness verification.
• Fraud detection and security services: To identify suspicious activity, duplicate accounts, and financial crime indicators.
• Cloud hosting and infrastructure providers: To store data and maintain Platform availability.
• Customer support tooling: To manage live chat and email communications.

All third-party Data Processors are engaged under contractual data processing agreements that require them to handle your data in accordance with applicable data protection standards and only for the purposes for which they were engaged.

6.2 Regulatory & Legal Disclosure

We may be required to disclose Personal Data to regulatory authorities, law enforcement agencies, or courts of competent jurisdiction where required by applicable law or pursuant to a valid legal order. We will take reasonable steps to notify affected Users of such disclosure where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the Platform's operations, Personal Data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections.

The Platform operates globally and your Personal Data may be transferred to, stored in, or processed in countries other than Pakistan. These countries may have data protection laws that differ from those in your home jurisdiction.

Where such transfers occur, we take reasonable steps to ensure that appropriate safeguards are in place — including contractual commitments with our Data Processors — to maintain a level of data protection consistent with applicable standards in our licensing jurisdiction.

By registering an Account and using the Platform, you acknowledge and consent to the transfer of your Personal Data outside Pakistan for the purposes described in this Policy.

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

Where retention beyond these periods is required by law or ongoing legal proceedings, we will retain the relevant data until those obligations are satisfied and then securely delete it.

The Platform uses cookies and similar technologies (including local storage and session tokens) to ensure correct Platform functionality, remember your preferences, and analyse how the Platform is used. We categorise our cookies as follows:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication tokens and security cookies. These cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Remember your preferences such as language, currency display (PKR), and layout settings to provide a consistent experience across sessions.
• Analytics Cookies: Collect anonymised or aggregated data about how Users navigate the Platform — such as which pages are most visited and where Users encounter errors — to help us improve performance.
• Marketing Cookies: Used where you have opted in to receive personalised promotions. These track which promotional content you have been shown or have engaged with.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect your experience on the Platform. Strictly necessary cookies cannot be disabled.

Subject to applicable data protection law and the limitations noted below, you have the following rights in relation to your Personal Data:

To exercise any of these rights, please contact us at [email protected] with your request clearly identified. We will acknowledge your request within a reasonable period and aim to respond substantively within thirty (30) days. Where requests are complex or numerous, we may extend this period by a further thirty (30) days with notification.

We implement appropriate technical and organisational security measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform
• Encryption of sensitive Personal Data at rest on our servers
• Role-based access controls limiting employee access to Personal Data on a strict need-to-know basis
• Multi-factor authentication requirements for staff accessing administrative systems
• Regular security audits and vulnerability assessments of Platform infrastructure
• Data breach incident response procedures, including notification obligations where applicable

While we take all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. You should take care to use strong, unique passwords for your Account and notify us immediately if you suspect any unauthorised access to your credentials.

The Platform is strictly restricted to individuals aged 18 years or older, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect Personal Data from individuals below the minimum eligible age.

If we become aware that a minor has registered an Account or submitted Personal Data, we will immediately close the Account and delete the associated Personal Data, subject to any legal retention obligations. Any funds deposited by a minor will be returned where possible to the original payment source.

If you believe that a minor has submitted Personal Data to the Platform, please contact us at [email protected] immediately.

With your explicit consent, we may send you marketing communications about bonuses, promotions, new game releases, sports betting events (such as PSL match-day offers, ICC tournament promotions, or UFC fight-night specials), and other Platform features. These communications are delivered via email and, where applicable, in-platform notifications.

You may withdraw your marketing consent at any time by:

• Clicking the "Unsubscribe" link in any marketing email we send
• Updating your communication preferences in your Account settings
• Contacting our support team at [email protected] and requesting removal from marketing lists

Withdrawing marketing consent does not affect your ability to receive transactional communications about your Account, including deposit confirmations, withdrawal status updates, security alerts, and KYC requests — these are sent on the basis of contractual necessity and cannot be opted out of while your Account remains active.

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform services. Where changes are material, we will endeavour to provide reasonable advance notice to registered Users via email or a prominently displayed Platform notification.

Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the updated Policy. We encourage you to review this Policy periodically to stay informed of how we handle your Personal Data.

The current version of this Policy is always accessible at https://zc111.cam/privacy-policy. The effective date at the top of this document indicates when the current version was last reviewed and updated.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the zc111 data team through the following channels:

• Email (data and privacy enquiries): [email protected]
• Live chat: Available 24/7 via the Platform's support interface

Please mark your email with the subject line "Privacy / Data Request" to ensure it is directed to the appropriate team member. We aim to acknowledge all data-related requests within 48 hours and to provide a substantive response within 30 days.

For responsible gambling enquiries, self-exclusion requests, or account closure, please visit our dedicated Responsible Gambling page or contact support directly.