zs111 Privacy Policy

1.1 For the purposes of applicable data protection law, the data controller in respect of personal data collected through the zs111 platform (accessible at zs111.app) is the operating entity behind the zs111 brand, operating under applicable international gaming regulations.

1.2 If you have any questions about this Privacy Policy or wish to exercise any of your data rights, you may contact our data protection point of contact at [email protected] (plain text — not a clickable link). We aim to respond to all data-related enquiries within 30 days.

2.1 zs111 collects the following categories of personal data in connection with your use of the platform:

• Identity Data: Full name, date of birth, gender, and nationality as provided during registration or identity verification.
• Contact Data: Mobile number (used for account creation, OTP delivery, and communications), email address where provided.
• Financial Data: Payment method identifiers (e.g. JazzCash mobile number, Easypaisa account reference, bank account last four digits), transaction amounts, deposit and withdrawal history. Full payment credentials are not stored by zs111 — they are processed by PCI-DSS compliant payment processors.
• Technical Data: IP address, device type, browser type and version, operating system, session timestamps, and approximate geolocation derived from IP.
• Usage Data: Betting history, game session logs, wagering amounts, bonus usage, product navigation patterns, and responsible gaming tool usage.
• Verification Data: Identity documents (CNIC, passport) and proof of address where requested for KYC/AML compliance. These are processed securely and retained only as required by applicable regulations.
• Communications Data: Records of correspondence between you and zs111 customer support, including chat transcripts, email exchanges, and support ticket histories.

3.1 Directly from you: When you register a zs111 account, complete identity verification, make a deposit or withdrawal, contact customer support, or interact with any feature of the platform that requires you to provide information.

3.2 Automatically: Through the technical operation of the platform. When you access zs111, our servers automatically record technical data including your IP address, device identifiers, session duration, and navigation paths. This data is collected via server logs and, where applicable, browser cookies and similar technologies.

3.3 From third parties: From payment processors (including JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and crypto payment gateways) to confirm the status and reference details of transactions. From identity verification service providers when we are required to verify your identity in connection with anti-money laundering (AML) or know-your-customer (KYC) obligations. From fraud detection services that help us identify and prevent prohibited activity on the platform.

4.1 zs111 processes your personal data for the following purposes, each supported by a lawful legal basis:

• Account creation and management — necessary for the performance of our contract with you as a registered user of zs111.
• Processing deposits, bets, and withdrawals — necessary for the performance of our contract with you and to comply with financial regulations.
• Identity verification and KYC/AML compliance — necessary to comply with our legal obligations under applicable anti-money laundering regulations.
• Fraud detection and security monitoring — necessary for the purposes of our legitimate interest in protecting the platform, other users, and the integrity of our services.
• Responsible gaming monitoring — necessary to comply with our legal and regulatory obligations; and in our legitimate interest in preventing gaming-related harm to users.
• Customer support communications — necessary for the performance of our contract with you.
• Marketing and promotional communications — where you have consented to receiving such communications, or where we have a legitimate interest in informing existing customers about relevant services. You may opt out at any time by contacting support.
• Platform improvement and analytics — in our legitimate interest in understanding how zs111 is used so that we can improve service quality, performance, and user experience for Pakistani players and others.

5.1 zs111 does not sell your personal data. We share data only with the following categories of recipients, and only to the extent necessary for the purpose in question:

• Payment Processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and crypto payment gateways receive transactional data necessary to process deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML service providers that assist zs111 in verifying user identities and screening against sanctions lists.
• Game Technology Providers: Software studios and live casino providers (such as Pragmatic Play and Evolution Gaming) may receive session identifiers to operate game functionality. These providers are contractually restricted from using data for any purpose other than service delivery.
• Fraud & Security Services: Third-party providers that assist in detecting and preventing fraudulent activity, account takeovers, and money laundering.
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or the request of a competent regulatory authority. zs111 will notify you of such disclosures where legally permitted to do so.
• Professional Advisers: Lawyers, auditors, and accountants where required in the ordinary course of business, subject to strict confidentiality obligations.

5.2 All third-party service providers engaged by zs111 are required to implement appropriate technical and organisational security measures and are contractually prohibited from using your personal data for their own purposes.

6.1 zs111 retains your personal data for as long as your account is active and for such further period as is required by applicable law or regulation. In particular:

• Account and identity data is retained for a minimum of five (5) years following account closure, as required by anti-money laundering regulations applicable to gaming operators.
• Transaction records (deposits, withdrawals, bet history) are retained for a minimum of five (5) years following the transaction date.
• Customer support correspondence is retained for three (3) years following the closure of the relevant support case.
• Technical and usage logs are retained for up to twelve (12) months, after which they are anonymised or deleted.

6.2 Where you request deletion of your account, zs111 will delete or anonymise personal data that we are not legally required to retain, within a reasonable period following verification of your identity and the processing of any outstanding transactions or disputes.

7.1 zs111 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit TLS/SSL encryption for all data transmitted between your device and zs111 servers;
• Encryption at rest for sensitive data stored in our databases;
• Role-based access controls restricting employee access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Two-factor authentication available to all users for account access, and mandatory for certain administrative functions;
• Automated anomaly detection for unusual login patterns, transaction volumes, and account activity.

7.2 Notwithstanding the above, no method of electronic transmission or storage is 100% secure. zs111 cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, zs111 will notify affected users and relevant authorities in accordance with applicable legal requirements.

8.1 zs111 uses cookies and similar technologies on its platform. Cookies are small text files stored on your device that help us deliver platform functionality, analyse usage, and personalise your experience.

8.2 The following categories of cookies are used on zs111:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, load-balancing cookies, and security tokens. These cannot be disabled.
• Functional Cookies: Store your preferences (such as language settings and responsible gaming tool configurations) to provide a consistent experience across sessions.
• Analytical Cookies: Used to understand how users interact with zs111 in aggregate, including which pages are visited most, where users drop off, and platform performance metrics. Data collected is anonymised before analysis.

8.3 zs111 does not deploy advertising or cross-site tracking cookies. You may configure your browser to block or delete cookies; however, disabling strictly necessary cookies will impair your ability to use the zs111 platform.

9.1 Subject to applicable law, you have the following rights in respect of your personal data held by zs111:

• Right of Access: You may request a copy of the personal data zs111 holds about you (commonly known as a Subject Access Request).
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where there is no legitimate reason for continued processing. Note that legal retention obligations may limit the scope of erasure.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, such as while the accuracy of data is contested.
• Right to Data Portability: You may request a copy of the data you have provided to zs111 in a structured, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

9.2 To exercise any of the above rights, contact zs111 at [email protected] (plain text). We will verify your identity before processing any request and will respond within 30 days. Complex or multiple requests may take up to 90 days, with notice provided.

10.1 zs111 is strictly an 18+ platform. We do not knowingly collect, process, or retain personal data from individuals under 18 years of age. Age verification is performed at the point of account registration.

10.2 If zs111 becomes aware that personal data has been collected from a person under 18 years of age, we will immediately suspend the associated account, delete the data collected (subject to any legal hold obligations), and take appropriate steps to prevent recurrence. If you are aware of an under-18 individual using zs111, please notify us at [email protected] (plain text).

11.1 zs111 operates as an international platform. Your personal data may be processed by zs111 or its service providers in jurisdictions outside Pakistan. Where data is transferred internationally, zs111 ensures that appropriate safeguards are in place — including contractual protections equivalent to applicable data protection standards — to maintain the same level of protection for your data regardless of where it is processed.

11.2 Payment processors operating in Pakistan (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah) process transactional data within Pakistan in accordance with applicable local financial regulations.

12.1 zs111 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform functionality. When changes are material, we will notify you via email to your registered address or through an on-platform notification prior to the changes taking effect.

12.2 The current version of this Privacy Policy is always available at zs111.app/privacy-policy. The "Last updated" date at the top of this page reflects the date of the most recent revision. Your continued use of zs111 after a Privacy Policy update constitutes acceptance of the revised policy.

13.1 For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the zs111 data protection team:

13.2 Please also refer to our Terms & Conditions and Responsible Gaming pages for further information about your rights and obligations as a zs111 user.