zh22 Privacy Policy

This Privacy Policy ("Policy") describes how zh22, operating the platform accessible at https://zh22.cam ("Platform", "we", "us", "our"), collects, uses, stores, shares and protects personal data provided by or generated by users ("you", "User", "Player") in the course of accessing and using our services.

zh22 serves an English-language audience across Pakistan, including players in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We take data privacy seriously and are committed to handling your personal information with transparency, care and respect for your rights.

By accessing the zh22 Platform and creating an account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue your use of the Platform.

The following terms carry these meanings throughout this Policy:

• "Personal Data" — any information that identifies or could reasonably identify a living individual, either directly (e.g., name, email address) or indirectly (e.g., account ID combined with other data).
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" — zh22, which determines the purposes and means of processing your Personal Data.
• "Data Processor" — a third party that processes Personal Data on behalf of zh22 under a data processing agreement (e.g., KYC providers, payment processors).
• "Cookies" — small data files stored on your device by the Platform to enable certain functionality and analytics.
• "KYC" — Know Your Customer verification procedures required to confirm a User's identity and comply with AML obligations.

zh22 collects Personal Data through three primary channels: information you provide directly, information generated automatically through your use of the Platform, and information received from third parties (such as KYC verification providers). The table below summarises the categories of data collected:

zh22 processes your Personal Data for the following specific purposes. We process only the minimum data necessary to fulfil each purpose — a principle known as data minimisation.

• Account Management: Creating, maintaining and administering your zh22 account, including authentication, security controls and preference management.
• Transaction Processing: Facilitating deposits and withdrawals through available payment channels, including familiar Pakistan payment references such as bank transfers. Payment method names referenced for context do not imply endorsement by those providers.
• Identity Verification (KYC): Verifying your identity and age in accordance with anti-money laundering requirements and the minimum age eligibility condition (18+ or higher minimum required by the operator/license jurisdiction).
• Fraud Prevention & Security: Detecting, investigating and preventing fraudulent transactions, account takeovers, bonus abuse and other prohibited conduct as defined in our Terms & Conditions.
• Responsible Gambling: Monitoring gameplay patterns to identify potential problem gambling indicators and applying account protections (e.g., deposit limits, self-exclusion) where applicable.
• Customer Support: Responding to your inquiries, complaints and support requests via live chat, email and other channels.
• Platform Improvement: Analysing aggregated usage data to improve platform performance, fix technical issues and enhance the user experience for Pakistani players.
• Marketing Communications: Sending promotional offers and platform updates to opted-in users. You may withdraw your marketing consent at any time through your account settings or by contacting support.
• Legal Compliance: Meeting our obligations under applicable law, including data retention requirements, regulatory reporting and cooperation with lawful authority requests.

zh22 processes your Personal Data only where a valid legal basis exists. The applicable legal bases are as follows:

• Contractual Necessity: Processing required to perform the contract between you and zh22, including account management, transaction processing and customer support.
• Legal Obligation: Processing required to comply with applicable laws, including KYC/AML verification, regulatory reporting and fraud investigation cooperation.
• Legitimate Interests: Processing carried out for zh22's legitimate interests, including fraud prevention, platform security and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: Processing carried out based on your freely given, specific and informed consent — in particular, for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

zh22 does not sell, rent or trade your Personal Data to third parties for commercial marketing purposes. We may share your data with trusted third parties only in the circumstances described below, and only to the extent necessary for each purpose:

• Payment Processors: To facilitate deposits and withdrawals. Transaction data is shared only as required to complete the financial operation.
• KYC / Identity Verification Providers: Specialist third-party services that verify your identity documents (e.g., CNIC, Passport) and confirm address details as part of our AML obligations.
• Fraud Detection & Security Partners: Service providers that assist zh22 in detecting suspicious activity, account takeovers and prohibited conduct on the Platform.
• Game Content Providers: Where gameplay data (such as bet amounts and session duration) must be passed to game studios or sports data providers to operate the products you access.
• Regulatory & Legal Authorities: zh22 may disclose Personal Data to competent regulatory bodies, law enforcement agencies or courts where required to do so by applicable law or in response to a lawful request.
• Business Transfers: In the event of a merger, acquisition or sale of all or substantially all of zh22's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

zh22 retains your Personal Data for as long as necessary to fulfil the purposes for which it was collected, including the satisfaction of any legal, regulatory, accounting or reporting requirements.

• Active Accounts: Personal Data is retained for the duration of your active account relationship with zh22.
• Account Closure: Following account closure, zh22 typically retains transaction records, identity verification documents and communication logs for a minimum period in accordance with applicable AML and financial record-keeping requirements. The specific retention period is governed by the operator's compliance documentation.
• Marketing Data: Where consent to marketing communications has been withdrawn, related contact data used solely for marketing purposes is removed from active mailing lists promptly, typically within 30 days of the withdrawal request.
• Anonymisation: Where Personal Data is no longer required for its original purpose but is of analytical value, zh22 may anonymise the data so that it can no longer be attributed to any individual, after which it falls outside the scope of this Policy.

zh22 uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure essential functions operate correctly, and gather aggregated analytics data to improve our service. The following categories of cookies are used:

• Essential Cookies: Required for core Platform functionality, including session management, authentication and security. These cannot be disabled without affecting core services.
• Analytical / Performance Cookies: Used to understand how users interact with the Platform — including which pages are visited, how long sessions last and where errors occur. Data is aggregated and does not identify individuals.
• Preference Cookies: Store your Platform settings such as language preference, odds format and responsible gambling limit configurations across sessions.
• Marketing Cookies (Opt-in only): Used to deliver relevant promotional content to opted-in users. These are only placed with your consent and can be withdrawn at any time.

You can manage, restrict or delete cookies through your browser settings. Please note that disabling essential cookies may impair the functionality of the zh22 Platform. Refer to your browser's help documentation for guidance on cookie management.

Subject to applicable law and any overriding legal obligations (such as AML retention requirements), you hold the following rights in relation to the Personal Data zh22 holds about you. To exercise any of these rights, please contact our support team at the details provided in Section 15.

We will respond to all valid data rights requests within the timeframe required by applicable law. We may need to verify your identity before processing a request to ensure that Personal Data is not disclosed to an unauthorised party.

zh22 implements appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Key security measures include:

• TLS/SSL Encryption: All data transmitted between your device and the zh22 Platform is encrypted in transit using current TLS protocols.
• Access Controls: Personal Data is accessible only to authorised personnel who require it for legitimate operational purposes, subject to role-based access restrictions.
• Two-Factor Authentication: Available for your account login to add an additional layer of protection beyond your password.
• Security Monitoring: zh22 monitors system activity for suspicious access patterns, unusual transaction behaviour and potential data breaches on a continuous basis.
• Third-Party Processor Vetting: All Data Processors engaged by zh22 are assessed for their data security practices prior to engagement and are contractually required to maintain adequate protections.

The zh22 Platform is strictly intended for adults aged 18 years and older — or the higher minimum age required by the operator/license jurisdiction. zh22 does not knowingly collect Personal Data from individuals below the eligible minimum age.

If we become aware that Personal Data has been collected from a minor — whether through fraudulent registration or otherwise — we will take immediate steps to delete that data, close the associated account and, where appropriate, report the matter to relevant authorities.

zh22 operates internationally and may transfer your Personal Data to countries outside your country of residence — including countries that may not have data protection laws equivalent to those in your jurisdiction. Such transfers occur where necessary to provide the Platform's services, including through third-party payment processors and KYC providers based in different jurisdictions.

Where Personal Data is transferred internationally, zh22 takes reasonable steps to ensure that appropriate safeguards are in place — such as contractual protections with receiving parties — to maintain a standard of data protection consistent with our obligations under applicable law.

By using the zh22 Platform, you acknowledge that your Personal Data may be transferred to and processed in countries other than Pakistan. If you have questions about specific transfer mechanisms, please contact us using the details in Section 15.

The zh22 Platform may reference or contextually mention third-party services — for example, familiar Pakistan payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — solely as informational context for Pakistani users. These references are not endorsements, affiliations or confirmations of availability.

zh22 is not responsible for the privacy practices or content of any third-party services, websites or platforms. If you access third-party services from or in connection with the zh22 Platform, you do so at your own risk and subject to those parties' own privacy policies. We encourage you to review the privacy policy of any service you interact with independently of zh22.

zh22 may update or revise this Privacy Policy from time to time to reflect changes in our data practices, applicable law or Platform functionality. Where changes are material, we will provide reasonable notice — typically by updating the "Last updated" date at the top of this page and, where appropriate, notifying registered users via email or in-platform notification.

Your continued use of the zh22 Platform after the publication of an updated Privacy Policy constitutes your acceptance of those changes. We recommend reviewing this page periodically to stay informed of how your data is handled.

If you have any questions, concerns or requests relating to this Privacy Policy or the way zh22 handles your Personal Data, please contact our Data Protection team. We aim to respond to all valid enquiries within a reasonable timeframe. Support is available 24/7 and Urdu-language assistance is available on request.