Privacy Policy

This Privacy Policy (hereinafter "Policy") is issued by z111 (hereinafter "z111", "we", "us" or "our") and applies to all personal data collected, processed or stored in connection with your use of the z111 platform, accessible at z111.cam (hereinafter "the Platform").

z111 is committed to protecting the privacy and security of all users (hereinafter "User", "you" or "your") who access our services, whether from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or elsewhere. We collect and process personal data only for clearly defined, legitimate purposes and in accordance with the privacy principles set out in this Policy.

By registering an account on z111, depositing funds or otherwise using our Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not accept this Policy, you should not use the Platform.

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can be used to identify a natural person, directly or indirectly, including but not limited to name, email address, national identity number, IP address and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means z111, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of z111 pursuant to a data processing agreement.
• "Consent" means a freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data for a defined purpose.
• "KYC Data" means identity verification documentation and supporting information collected in connection with z111's Know Your Customer obligations, including government-issued ID, proof of address and source-of-funds documentation.
• "Cookies" means small text files stored on your device by the Platform for session management, analytical and functional purposes.
• "Retention Period" means the defined duration for which z111 stores a category of Personal Data before secure deletion or anonymisation.

z111 collects personal data through a number of channels and interactions, including account registration, KYC verification, financial transactions, customer support interactions and your ordinary use of the Platform. The categories of data we collect are as follows:

3.1 Identity & Registration Data

• Full legal name as it appears on official documentation.
• Date of birth (for age verification purposes).
• Residential address, including city and country.
• Email address and mobile phone number.
• Username and encrypted password.

3.2 KYC & Verification Data

• Copies of government-issued photo identification (e.g., CNIC, passport).
• Proof of address documentation (e.g., utility bill, bank statement).
• Where required, source-of-funds documentation to satisfy anti-money laundering obligations.
• Facial verification images where biometric verification is used.

3.3 Financial & Transaction Data

• Deposit and withdrawal records, including method, amount and timestamp.
• Payment method identifiers (e.g., bank account reference, wallet ID — not full card numbers).
• Betting history, wager amounts, outcomes and bonus utilisation.
• Account balance at key timestamps for audit and compliance purposes.

3.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system and browser version.
• Session duration, pages visited and features used within the Platform.
• Login timestamps and session identifiers.

3.5 Communications Data

• Support chat transcripts and email correspondence with z111.
• Feedback and survey responses where voluntarily provided.
• Marketing preference records, including opt-in and opt-out history.

z111 uses your personal data for the following purposes, each of which is necessary to provide the Platform's services, comply with legal obligations, or pursue our legitimate business interests:

z111 does not use personal data for automated decision-making that produces significant legal or similarly significant effects without human review, except where required by applicable fraud-detection or AML obligations and where appropriate safeguards are in place.

Each processing activity conducted by z111 rests on one or more of the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the agreement formed when you register an account, including account management, transaction processing and KYC verification.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements and record-keeping mandates imposed by z111's operating jurisdiction.
• Legitimate interests: Processing carried out in pursuit of z111's legitimate business interests, such as fraud prevention, platform security, abuse detection and product improvement — where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your specific, informed agreement, such as the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

z111 does not sell, rent or trade personal data to third parties. We may share personal data in the following limited circumstances:

6.1 Service Providers & Data Processors

z111 engages third-party service providers to assist in operating the Platform. These may include payment processing providers, KYC and identity verification vendors, fraud detection technology suppliers, cloud infrastructure providers, customer support platform operators and data analytics tools. All such providers are bound by data processing agreements that restrict their use of personal data to the specific purposes for which it is shared.

6.2 Legal and Regulatory Disclosure

z111 may disclose personal data to law enforcement agencies, financial intelligence units, regulatory bodies or courts where required to do so by applicable law or by order of a competent authority. This includes disclosures required in connection with AML investigations, suspected fraud or other criminal activities.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of z111's business, personal data may be transferred to the acquiring entity as part of the transaction. Users will be notified of any such transfer and of any change to the Privacy Policy that results from it.

6.4 With Your Consent

z111 will not share your personal data with any third party for any purpose not described in this Policy without your explicit prior consent.

z111 uses cookies and similar tracking technologies to maintain session continuity, improve Platform functionality, analyse user behaviour in aggregate and, where applicable, serve relevant content to returning users.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security tokens.
• Functional Cookies: Store your preferences such as language settings, odds format (decimal or fractional) and display options to personalise your experience.
• Analytical Cookies: Collect anonymised data on how the Platform is used — page visit frequency, session duration and feature interactions — to help us improve the service.
• Marketing Cookies: Used only where you have provided consent. These may track your interactions with z111 content to assess the effectiveness of marketing campaigns.

7.2 Managing Cookies

You may configure your browser to reject non-essential cookies at any time. Note that disabling certain categories of cookies may limit Platform functionality, including session persistence and personalisation features. Most modern browsers provide cookie management settings accessible via the browser's privacy or settings menu.

z111 operates as an international platform and may transfer personal data to, or process it in, jurisdictions outside your country of residence. Where personal data is transferred internationally, z111 ensures that appropriate safeguards are in place to protect your data to the standard required under the data protection laws of z111's operating jurisdiction.

Safeguards for international transfers may include, as applicable: standard contractual clauses incorporated into agreements with data processors; adequacy decisions where the receiving jurisdiction provides an equivalent level of data protection; and binding corporate rules where data is transferred within a corporate group.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan. Such transfers are conducted in compliance with applicable legal requirements and with appropriate protective measures in place.

z111 retains personal data for the minimum period necessary to fulfil the purposes described in this Policy, or for such longer period as may be required by applicable law. The following general retention guidelines apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be attributed to any identified individual. Anonymised aggregated data may be retained indefinitely for statistical or analytical purposes.

Subject to applicable law and certain limitations set out below, you hold the following rights in respect of your personal data processed by z111:

To exercise any of the above rights, please contact z111 via the support email address provided in Section 14 of this Policy. We will acknowledge your request within five business days and provide a substantive response within 30 calendar days. We may request identity verification before fulfilling a data rights request to protect against fraudulent access.

z111 is strictly an adults-only Platform. Registration and use of the Platform is prohibited for any person under the age of 18, or under the higher minimum age required by the operator's licensing jurisdiction. z111 does not knowingly collect personal data from individuals below the applicable minimum age.

Age verification is a mandatory component of the KYC process, and we apply risk-based checks to identify and prevent underage access. Where z111 identifies that personal data has been collected from an underage individual, that data will be securely deleted and the associated account permanently closed without delay.

If you have reason to believe that a minor has registered on the Platform or submitted personal data to z111, please contact our support team immediately so that we can take appropriate action.

z111 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including KYC documentation and financial records.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for internal administrative systems.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures governing notification and containment in the event of a data breach.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You are responsible for maintaining the security of your account credentials and should notify z111 promptly if you suspect any unauthorised access to your account.

In the event of a data breach that poses a risk to your rights and freedoms, z111 will notify affected users in accordance with applicable legal requirements and will take all reasonable steps to mitigate any harm.

z111 reserves the right to update or amend this Privacy Policy at any time. The date of the most recent revision is displayed at the top of this page. Where a material change is made — one that meaningfully affects how we use your personal data or that diminishes your data rights — we will provide advance notice via a prominent notice on the Platform or by email to your registered address where practicable.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of and agreement to the revised terms. We encourage you to review this Policy periodically to remain informed of how your data is handled.

If you have questions about any change to this Policy, please contact our support team before continuing to use the Platform.

If you have questions, concerns or complaints regarding this Privacy Policy, or wish to exercise any of your data rights as described in Section 10, please contact z111 through the following channels. All correspondence should reference your registered username or Account reference number where possible.

Data Enquiries & Subject Access Requests:
[email protected] (Plain text only — this address is not a clickable link)

Live Chat Support:
Available via the Platform's chat widget. Available 24/7 as per operator-provided information. For formal data rights requests, email is preferred to ensure a documented record.

Response Timelines:
z111 will acknowledge data rights requests within 5 business days and provide a substantive response within 30 calendar days. Complex requests may require up to an additional 60 days, in which case you will be notified of the extension within the initial 30-day period.

For details about our Terms and Conditions, please visit the Terms & Conditions page. For responsible gambling tools and information, visit our Responsible Gambling page.