zc88 Privacy Policy —
How We Collect, Use, and Protect Your Personal Data

1.1 zc88 ("the Company", "we", "us", "our") is committed to protecting the privacy, security, and personal data of every individual who interacts with the zc88 platform. This Privacy Policy ("Policy") sets out the basis on which personal data we collect from you — or that you provide to us — will be processed by us.

1.2 This Policy applies to all users of the zc88 platform, including registered Members, visitors who browse without registering, and individuals who contact zc88 through any support or communication channel. References to "you" or "the Member" throughout this Policy include all such individuals.

1.3 zc88 processes personal data in compliance with applicable data protection legislation and the requirements of its international gaming licence, which impose strict standards for data collection, storage, use, and subject rights.

1.4 This Policy should be read alongside the zc88 Terms & Conditions and Responsible Gaming Policy. Together, these documents form the complete framework governing your relationship with the zc88 platform. In the event of any conflict between this Policy and those documents on matters of data protection, this Privacy Policy shall prevail.

2.1 zc88 collects personal data that is necessary for the lawful operation of an internationally licensed online gaming platform. The categories of data we collect are set out in the table below:

2.2 zc88 does not collect or process special categories of sensitive personal data (such as biometric data, health information, or political opinions) except where expressly required to satisfy age verification or identity confirmation obligations under our licensing requirements.

2.3 You are not obligated to provide personal data to zc88; however, where data is required for registration, KYC, or payment processing, failure to provide the requested information will prevent us from opening an account for you or processing your transactions.

3.1 Data You Provide Directly. zc88 collects personal data directly from you through the following means:

• Completing the account registration form on the zc88 platform;
• Submitting KYC verification documents (CNIC scan, proof of address, selfie);
• Initiating deposit or withdrawal transactions using JazzCash, EasyPaisa, bank transfer, or any other supported payment method;
• Contacting zc88 customer support via live chat, email, or any other communication channel;
• Completing surveys, feedback forms, or promotional competitions on the Platform;
• Configuring responsible gaming tools within your account dashboard.

3.2 Data Collected Automatically. When you access the zc88 platform — whether through the website at zc88.lol or the Android mobile application — certain technical and usage data is collected automatically through cookies, web beacons, server logs, and similar technologies. This data includes your IP address, device specifications, browser information, and behavioural patterns within the Platform. See Section 8 for detailed information regarding our use of cookies.

3.3 Data Received from Third Parties. zc88 may in certain circumstances receive personal data about you from authorised third-party sources, including:

• Identity verification service providers used to authenticate your CNIC and confirm your age;
• Payment processors and financial institutions (including JazzCash and EasyPaisa) in connection with deposit and withdrawal transaction verification;
• Fraud detection and anti-money laundering compliance services that cross-reference against sanctions and watchlist databases;
• Responsible gaming bodies and self-exclusion registries to verify your self-exclusion status.

4.1 zc88 processes your personal data only where a lawful basis for processing exists. The table below sets out the primary purposes for which we process personal data and the corresponding legal basis in each case:

5.1 zc88 does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. We will not disclose your data to any external party except in the specific circumstances described in this Section.

5.2 Service Providers. zc88 engages carefully selected third-party service providers to assist in delivering the Platform's services. These providers process personal data on our behalf, under strict contractual data processing agreements that require them to maintain the confidentiality and security of your data. Categories of service providers engaged by zc88 include:

• Payment processors — JazzCash, EasyPaisa, bank transfer partners, and USDT TRC20 processing services, to execute financial transactions;
• Identity verification providers — to authenticate CNIC documents and confirm age;
• Gaming software providers — to deliver game content and live casino streams to the Platform;
• Cloud hosting providers — to securely host Platform data on infrastructure maintained to enterprise security standards;
• Fraud prevention and AML services — to screen transactions against financial crime databases;
• Customer support platform providers — to manage live chat and email communications.

5.3 Legal and Regulatory Disclosure. zc88 may disclose personal data to regulatory authorities, law enforcement agencies, or gaming licensing bodies where required to do so by applicable law, court order, or enforceable governmental request. In such cases, zc88 will disclose only the minimum amount of data necessary to satisfy the legal obligation.

5.4 Responsible Gaming Registries. Where a Member requests self-exclusion on the zc88 Platform, certain data may be shared with responsible gaming registries maintained by the relevant gaming authority to prevent the Member from accessing other licensed platforms during the exclusion period, where such registry arrangements are in place.

5.5 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of the Company's assets, personal data held by zc88 may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection obligations being maintained by the acquiring entity.

6.1 zc88 retains your personal data for no longer than is necessary for the purposes for which it was collected, and in accordance with applicable legal retention requirements. In practice, the following general retention periods apply:

• Account and identity data — retained for the duration of your membership and for a minimum of five (5) years following account closure, to satisfy anti-money laundering record-keeping obligations;
• Financial transaction records — retained for a minimum of five (5) years from the date of the transaction, as required by financial crime compliance standards;
• Gaming activity records — retained for a minimum of three (3) years from the date of each gaming session, to facilitate dispute resolution and responsible gaming monitoring;
• Customer support communications — retained for two (2) years from the date of the interaction, or longer where relevant to an ongoing dispute;
• Technical and usage data — retained for up to twelve (12) months from collection;
• Responsible gaming records — self-exclusion and intervention records are retained for the full duration of the exclusion period and for a minimum of five (5) years thereafter.

6.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to any identifiable individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

7.1 zc88 implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption — applied to all data in transit between your device and the zc88 servers, including all login sessions, financial transactions, and personal data submissions;
• At-rest encryption — all stored personal data and financial records are encrypted at rest using industry-standard encryption algorithms;
• Two-Factor Authentication (2FA) — available to all Members and strongly recommended to secure account access;
• Access controls — personal data is accessible only to authorised zc88 personnel on a strict need-to-know basis, with access rights reviewed periodically;
• Security monitoring — continuous automated monitoring for suspicious access patterns, unusual login attempts, and anomalous transaction behaviour;
• Regular security audits — the Platform undergoes periodic third-party security assessments to identify and remediate vulnerabilities.

7.2 Despite these measures, no method of data transmission or storage is 100% secure. zc88 cannot guarantee absolute security of your data. In the event of a data breach that is likely to result in a risk to your rights and freedoms, zc88 will notify affected Members and relevant regulatory authorities without undue delay and in accordance with applicable legal requirements.

7.3 Members are reminded of their responsibility to maintain the security of their own account credentials. zc88 will never request your password through email, live chat, SMS, or any other channel.

8.1 zc88 uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the Platform and to personalise your experience. A "cookie" is a small text file placed on your device when you access a website or application.

• Strictly Necessary Cookies — essential for the Platform to function. These include session authentication cookies that keep you logged in during your zc88 session. These cookies cannot be disabled without preventing access to core Platform features;
• Performance and Analytics Cookies — collect anonymised information about how Members use the Platform (pages visited, time on page, error reports) to help us improve performance and game loading times;
• Functionality Cookies — remember your preferences (language, game lobby view, responsible gaming settings) to provide a personalised experience;
• Fraud Prevention Cookies — assist in detecting and preventing fraudulent access attempts and multiple account creation by cross-referencing device fingerprints;
• Marketing Cookies — used to measure the effectiveness of promotional campaigns, where you have provided consent for marketing communications. zc88 does not use third-party advertising network cookies.

8.3 You may control cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, blocking strictly necessary cookies will affect the functionality of the zc88 platform, including your ability to log in and complete transactions. Detailed instructions for managing cookies are available through your browser's help documentation.

9.1 As a data subject whose personal data is processed by zc88, you hold the following rights with respect to your personal data. These rights may be exercised at any time by contacting zc88 through the channels set out in Section 13.

10.1 zc88 implements age verification procedures at the point of registration and as part of the KYC identity check process to confirm that all Members meet the minimum age requirement of 21 years. Any individual who is found to have provided false age information during registration is in breach of the zc88 Terms & Conditions.

10.2 If zc88 becomes aware at any point that personal data has been collected from a person under the age of 21 — whether through registration, KYC discovery, or third-party notification — the Company will immediately suspend the relevant account, delete all associated personal data to the extent permitted by law, and return any deposited funds to the source payment method where technically feasible.

10.3 Parents or guardians who believe that a minor may have registered on the zc88 platform should contact our support team immediately at the details provided in Section 13. We will investigate all such reports with the highest priority and take immediate protective action.

11.1 The zc88 platform may contain references to third-party services — particularly game software providers and payment processors — whose own platforms may be accessible through links or integrations. This Privacy Policy applies solely to the zc88 platform and does not govern the data practices of any third-party service.

11.2 zc88 has no control over the privacy practices of third-party platforms and accepts no responsibility for the manner in which those platforms collect, store, or use your personal data. Members are encouraged to review the privacy policies of any third-party service before providing personal data to that service directly.

11.3 Where personal data is shared with third-party service providers engaged by zc88 (as described in Section 5.2), those providers are contractually bound to process your data only on zc88's instructions and in accordance with data protection standards equivalent to those described in this Policy.

12.1 zc88 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable data protection law, our operational practices, or our licensing requirements. The "Last Updated" date at the top of this document will be revised each time the Policy is amended.

12.2 Where changes to this Policy are material in nature — meaning they significantly affect how we process your personal data or the rights you hold — zc88 will provide advance notice to registered Members through the email address on file and/or through a prominent notice on the Platform, no less than seven (7) days before the changes take effect.

12.3 Your continued use of the zc88 platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you must cease using the Platform and may request account closure in accordance with the procedures described in the Terms & Conditions.

12.4 We recommend that Members review this Privacy Policy periodically to stay informed of how zc88 handles personal data. The current version of this Policy is always available at zc88.lol/privacy-policy.

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the manner in which zc88 processes your personal data, please contact us through the following channels:

• Email (Privacy & Data Enquiries): [email protected] — please use the subject line "Privacy Policy Enquiry" or "Data Rights Request" for fastest routing;
• Live Chat: Available 24/7 through the in-Platform chat interface. For data rights requests, please confirm your identity and state that your enquiry relates to a privacy matter;
• Account Dashboard: Marketing preferences, communication opt-outs, and certain data access functions are available directly through your zc88 account settings.

13.2 zc88 aims to respond to all privacy-related enquiries within five (5) business days of receipt. Formal data rights requests (access, erasure, portability, etc.) will receive a substantive response within thirty (30) calendar days.

13.3 If you are not satisfied with our response to a privacy concern or data rights request, you have the right to escalate your complaint to the relevant data protection authority in the jurisdiction governing this Policy, or to the gaming licensing authority that oversees the zc88 platform's compliance programme.