ZJ77 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how ZJ77 ("ZJ77", "we", "us", "our"), operator of the online gaming platform accessible at https://zj77.cam, collects, uses, stores, shares and protects the personal data of Users ("you", "your") who access, register on or interact with the ZJ77 Platform.

This Policy applies to all personal data collected through the ZJ77 website, mobile site, applications, support communications and any other channel through which ZJ77 interacts with its Users. It forms part of ZJ77's wider legal framework alongside the Terms & Conditions.

By registering an Account, depositing funds, placing a wager or otherwise using the Platform, you acknowledge that you have read and understood this Policy and you consent to the processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you must not use the ZJ77 Platform.

2. Definitions

• "Account" — the registered User account on the ZJ77 Platform.
• "Controller" — the entity that determines the purposes and means of processing personal data. ZJ77 acts as Controller for data processed in connection with the Platform.
• "Personal Data" — any information that identifies or could identify a living individual, including name, contact details, date of birth, financial data and device identifiers.
• "Platform" — the ZJ77 website, mobile interface, applications and all associated services at https://zj77.cam.
• "Processor" — a third party that processes personal data on ZJ77's behalf under a data processing agreement.
• "Sensitive Personal Data" — personal data warranting heightened protection, including identification documents, financial records and data relating to health (e.g., responsible-gambling assessments).
• "User" — any individual who accesses, registers on or uses the ZJ77 Platform.

3. Data We Collect

3.1 Registration Data

When you create an Account, we collect: full legal name, date of birth, residential address (including city — e.g., Karachi, Lahore, Islamabad), email address, telephone number (if provided) and username and password credentials.

3.2 KYC & Verification Documents

To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we collect and process copies of government-issued identity documents (such as CNIC, passport or driving licence), proof of address documentation (such as utility bills or bank statements dated within 90 days), and, where required, documentation relating to your source of funds or payment methods used.

3.3 Financial & Transaction Data

We collect records of deposits, withdrawals, wagering transactions, bonuses claimed and associated payment method details. Payment references may include data relating to the payment rails used — Easypaisa, JazzCash, Raast and bank transfers are referenced as educational context only; none of these providers are affiliated with or endorse ZJ77.

3.4 Technical & Device Data

Automatically collected when you access the Platform: IP address, device type and operating system, browser type and version, referring URLs, session duration and pages visited, and geolocation data (country/region level).

3.5 Communications Data

Records of communications between you and ZJ77 support staff, including Live Chat transcripts, email correspondence and help ticket history, are retained for quality assurance and dispute resolution purposes.

3.6 Responsible Gambling Data

If you interact with responsible gambling tools — setting deposit limits, requesting self-exclusion or completing a self-assessment — we record this information to enable and enforce the requested controls and to fulfil our duty of care obligations.

4. Data Processing

ZJ77 processes your personal data for the following purposes:

• Account Management: Creating, maintaining and administering your Account, including authentication and access control.
• Service Delivery: Providing access to sports betting markets (including cricket, PSL/T20 and ICC events), casino games, live dealer tables, slots and other Platform features.
• KYC/AML Compliance: Verifying your identity, assessing financial risk and complying with applicable anti-money-laundering and counter-terrorist-financing obligations.
• Payment Processing: Facilitating deposits, processing withdrawal requests and maintaining financial records.
• Fraud Prevention & Security: Detecting, investigating and preventing fraudulent activity, collusion, bonus abuse and other breaches of the Terms & Conditions.
• Responsible Gambling: Administering self-imposed limits, self-exclusion requests and other responsible-gambling controls you have activated.
• Customer Support: Responding to enquiries, resolving disputes and managing complaints.
• Marketing (Where Consented): Sending promotional communications, including information about bonuses, cricket betting markets and new platform features, where you have given explicit consent or where a legitimate-interest basis applies to existing customers.
• Platform Improvement: Analysing usage patterns and technical data to improve platform performance, user experience and product development.
• Legal Compliance: Meeting obligations imposed by applicable law, court orders or regulatory requirements.

5. Lawful Basis for Processing

ZJ77 relies on the following lawful bases for processing personal data:

• Contractual Necessity: Processing required to fulfil the contract represented by the Terms & Conditions — including Account management, service delivery and payment processing.
• Legal Obligation: Processing required to comply with applicable legal requirements, including KYC/AML verification, financial record retention and fraud reporting.
• Legitimate Interests: Processing that serves ZJ77's legitimate business interests — including fraud prevention, security monitoring and service improvement — where these interests are not overridden by your rights and interests.
• Consent: Where we rely on consent — principally for non-essential marketing communications and non-essential cookies — you have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Third-Party Data Sharing

ZJ77 does not sell, rent or trade your personal data. We may share data with the following categories of third party only for the defined purposes described:

• Identity Verification Providers: Authorised KYC service providers who process identity and address verification documents on our behalf under strict confidentiality and data processing agreements.
• Payment Processors: Third-party payment service providers who process deposit and withdrawal transactions. These providers operate under their own privacy policies and ZJ77 is not responsible for their data practices beyond the scope of our processing instructions.
• Analytics Providers: Platform analytics and performance monitoring tools that process technical and usage data under pseudonymisation and data minimisation standards.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order or regulatory direction, ZJ77 may disclose personal data to competent authorities. We will notify you of such disclosures where legally permissible.
• Fraud Prevention Networks: Shared fraud intelligence databases used to identify and prevent fraudulent activity, multi-accounting and financial crime.

7. International Data Transfers

ZJ77 may process and store personal data in jurisdictions outside Pakistan, including the jurisdictions in which ZJ77's servers, service providers and KYC partners operate. These jurisdictions may not have data protection laws equivalent to those in your home country.

Where personal data is transferred internationally, ZJ77 applies appropriate safeguards including contractual data processing agreements with third-party processors. Pakistani users should note that Pakistan's data privacy framework may not extend to data processed or stored abroad. This is not legal advice — please consult an independent legal adviser for guidance on cross-border data rights applicable to your situation.

8. Cookies & Tracking Technologies

ZJ77 uses cookies and similar tracking technologies to operate, secure and improve the Platform. The table below describes the categories of cookies we use:

You may manage cookie preferences through your browser settings. Blocking all cookies may impair Platform functionality. ZJ77 does not use cookies to collect special category personal data directly through cookie mechanisms.

9. Data Retention

ZJ77 retains personal data for no longer than necessary for the purpose for which it was collected, subject to the following:

• Account Data: Retained for the duration of your active Account and for a defined period after Account closure, in accordance with ZJ77's data retention schedule and applicable legal requirements.
• KYC/AML Records: Retained for the minimum period required by the applicable anti-money-laundering and financial crime compliance framework — typically a mandated period (often five years in many jurisdictions) after the business relationship ends.
• Transaction Records: Financial transaction records retained for the period required by applicable accounting and regulatory obligations.
• Support Communications: Retained for a reasonable period for quality assurance and dispute resolution purposes.
• Analytics Data: Aggregated or pseudonymous analytics data may be retained for longer periods as it does not identify individual Users.

When personal data is no longer required, it is securely deleted or anonymised such that it can no longer be attributed to an identified individual.

10. User Rights

Subject to applicable law and the conditions set out below, you hold the following rights in relation to your personal data processed by ZJ77:

To exercise any of the above rights, contact our support team using the details in Section 15. We will respond within a reasonable timeframe. Note that exercising certain rights (in particular erasure) may result in Account closure where the data concerned is essential to the continued provision of services.

11. Children & Minors

The ZJ77 Platform is strictly for adults aged 18 or above — or the higher minimum age required by the applicable operator or licence jurisdiction. ZJ77 does not knowingly collect personal data from individuals below the applicable minimum age. If we become aware that personal data has been collected from a minor, we will take prompt steps to delete that data and close the associated Account.

If you believe a minor has registered an Account on ZJ77, please contact our support team immediately using the details in Section 15. We take age verification seriously and will investigate all reports promptly.

12. Data Security

ZJ77 applies appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ZJ77 servers.
• Access controls limiting staff access to personal data on a need-to-know basis with role-based permissions.
• Encrypted storage of sensitive personal data at rest.
• Regular security assessments and monitoring of the Platform infrastructure.
• Third-party processor vetting and contractual data security requirements.

No system is completely immune from security incidents. In the event of a personal data breach that poses a material risk to your rights and interests, ZJ77 will notify affected Users in accordance with applicable legal requirements. If you suspect your Account has been compromised, contact our support team immediately.

13. Pakistan-Specific Notice

ZJ77 is an English-language platform primarily serving Pakistani users. The following considerations are specific to users accessing the Platform from Pakistan:

• ZJ77 does not claim compliance with any specific current Pakistani data protection legislation. Pakistan's data privacy regulatory framework continues to develop and users should monitor applicable law in their jurisdiction.
• Personal data may be transferred to and processed in jurisdictions outside Pakistan. Pakistani data protection law may not govern such transfers.
• ZJ77 does not share personal data with Pakistani government authorities unless legally compelled to do so.
• KYC documents submitted (such as CNIC copies) are processed only for identity verification purposes and are retained only for the minimum legally required period.
• Familiar Pakistani payment references — Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — appear on ZJ77 as educational context only. These providers have their own privacy policies entirely separate from and independent of this Policy.

This section does not constitute legal advice. Pakistani users should seek independent legal guidance on applicable data protection rights in their jurisdiction.

14. Amendments to This Policy

ZJ77 reserves the right to amend this Privacy Policy at any time. Material changes will be communicated to registered Users via the email address on file or through a prominent notice on the Platform. The "Last Updated" date at the top of this page indicates the most recent revision. Your continued use of the Platform after notification of changes constitutes acceptance of the updated Policy. If you do not accept any amendment, you must cease using the Platform.

15. Contact Us

For any questions, requests to exercise your data rights, privacy complaints or other privacy-related matters, please contact our Data Privacy team through the following channel: