Privacy Policy — zs444

This Privacy Policy ("Policy") is issued by zs444 ("we", "us", "our", "Platform") and applies to all personal data collected from or about you ("User", "you", "your") in connection with your registration, access to and use of the website located at https://zs444.cam and all associated services (collectively, the "Services").

We are committed to protecting the privacy and security of your personal data. This Policy has been drafted in accordance with internationally recognised data protection principles and sets out how we collect, use, store, share and safeguard your personal information.

By registering an account or otherwise using the Services, you confirm that you have read and understood this Policy. If you do not agree with its terms, you must not use the Services. This Policy should be read alongside our Terms & Conditions, which are available at zs444.cam/terms-conditions.

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, financial information and device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, alteration, retrieval, use, disclosure or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, zs444.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller.
• "KYC" means Know Your Customer — the identity verification process required before certain account actions, including withdrawals, may be completed.
• "Cookie" means a small text file placed on your device by the Platform for the purposes of session management, analytics or personalisation.
• "Services" has the meaning assigned to it in Section 1 of this Policy.

zs444 acts as the Data Controller for personal data collected through the Platform. As Data Controller, we determine the purposes for which your personal data is processed and are responsible for ensuring that such processing is carried out lawfully and in accordance with applicable data protection requirements.

For questions relating to data control or to exercise your rights as a data subject, please contact us using the details provided in Section 16 of this Policy.

We collect the following categories of personal data in connection with your use of the Services:

4.1 Registration & Identity Data

• Full legal name and username
• Date of birth (for age verification)
• Residential address, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Email address and mobile phone number
• Government-issued identity document details submitted during KYC

4.2 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts in PKR
• Payment method references (e.g., mobile wallet account identifiers, bank account details) — these are collected solely for the purpose of processing your transactions
• Betting history, game play records and account balance data

4.3 Technical & Usage Data

• IP address, browser type and version, operating system
• Device identifiers and mobile device type
• Pages visited, time spent on Platform, clickstream data
• Session logs and login timestamps

4.4 Communications Data

• Records of correspondence with our support team via live chat or email
• Feedback and complaint submissions

We collect personal data through the following means:

• Directly from you — when you register an account, complete your profile, submit KYC documents, make deposits or withdrawals, contact support, or respond to promotional offers.
• Automatically — through cookies, web beacons, server logs and similar tracking technologies when you navigate the Platform. See Section 11 for more detail on our cookies practice.
• From third parties — where necessary for identity verification, fraud prevention or compliance purposes, we may receive data from identity verification providers, payment processors, and fraud detection services.

We process your personal data on one or more of the following legal bases:

1. Contractual necessity: Processing required to provide the Services under our Terms & Conditions, including account management, transaction processing and customer support.
2. Legal obligation: Processing required to comply with applicable regulatory requirements, including anti-money laundering obligations, KYC verification and responsible gambling duties.
3. Legitimate interests: Processing carried out for our legitimate business interests — including fraud prevention, platform security, analytics and service improvement — where those interests are not overridden by your fundamental rights.
4. Consent: Where you have provided express consent, such as opting in to receive marketing communications. You may withdraw consent at any time by contacting support.

Your personal data is processed for the following specific purposes:

• Account creation and management: To register, verify and maintain your user account on zs444.
• Transaction processing: To facilitate deposits and withdrawals, including verification of payment method ownership and processing of PKR-denominated transactions.
• KYC and compliance: To verify your identity, confirm your age (18+ or the applicable higher minimum), perform anti-money laundering checks and comply with other regulatory obligations.
• Customer support: To respond to your enquiries, resolve disputes and process complaints.
• Responsible gambling: To monitor betting patterns that may indicate problem gambling behaviour and to administer self-exclusion and limit-setting tools.
• Platform security: To detect and prevent fraud, account abuse, chargebacks and other prohibited activities.
• Analytics and improvement: To understand how users interact with the Platform and to improve user experience, mobile performance and product quality.
• Marketing communications: To send promotional offers and updates — only where you have given consent and subject to your opt-out preferences.

We do not sell, rent or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients for the purposes described in this Policy:

• Payment service providers: To facilitate deposit and withdrawal transactions. References to payment rails such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are made for familiarity only — data shared with any payment provider is subject to that provider's own terms and privacy practices.
• Identity verification providers: To conduct KYC, age verification and document authentication in support of our regulatory compliance obligations.
• Fraud prevention and security services: To identify and prevent fraudulent activity, account abuse and money laundering.
• Technology and platform providers: Third-party game studios, data hosting providers and infrastructure partners who process data on our behalf under data processing agreements.
• Regulatory and law enforcement authorities: Where we are required to disclose data by applicable law, court order or at the request of a competent regulatory authority.

We retain your personal data for as long as your account remains active and for a further period required by our legal, regulatory and contractual obligations. In practice:

• Account and identity data is retained for the duration of your account and for a minimum period following closure as required by applicable anti-money laundering and gambling regulatory obligations.
• Transaction records are retained for the period required by applicable financial and gambling regulations.
• Communications data is retained for a reasonable period to enable dispute resolution and quality assurance.
• Marketing preferences and consent records are retained until you withdraw consent or the consent record is no longer required.

After the applicable retention period, personal data is either securely and permanently deleted, or anonymised so that it can no longer be linked to you as an individual.

Subject to applicable law and our legitimate processing interests, you have the following rights in relation to your personal data:

• Right of Access: You may request a copy of the personal data we hold about you.
• 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 it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example while the accuracy of the data is contested.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request a copy of your data 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 that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact our support team using the details in Section 16. We will respond to verified requests within a reasonable timeframe in accordance with applicable requirements.

zs444 uses cookies and similar tracking technologies to enable essential platform functionality, improve performance, and analyse usage patterns. The categories of cookies we use are as follows:

• Essential cookies: Strictly necessary for the Platform to function, including session management and authentication. These cannot be disabled without impairing the Services.
• Analytics cookies: Used to collect aggregated, anonymised data about how users navigate the Platform, enabling us to improve usability and mobile performance.
• Preference cookies: Used to remember your settings and preferences across visits.
• Marketing cookies: Used, where you have consented, to deliver relevant promotional content. You may opt out of marketing cookies at any time through your browser settings or by contacting support.

You can control cookie preferences through your browser settings. Disabling essential cookies may affect your ability to use the Services.

The Services are strictly intended for adults aged 18 years and above, or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.

If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered an account on zs444, please contact our support team immediately using the details in Section 16.

In the course of operating the Services, your personal data may be transferred to, stored in, or processed in countries outside your country of residence. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection standards.

These safeguards may include standard contractual clauses, data processing agreements with adequate protections, or transfers to jurisdictions that provide an adequate level of protection as recognised by applicable law. By using the Services, you acknowledge and consent to such transfers.

We implement and maintain appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration or disclosure. These measures include:

• TLS encryption for all data in transit between your device and our servers
• Access controls restricting personal data access to authorised personnel only, on a need-to-know basis
• Regular security reviews and vulnerability assessments
• Secure, access-controlled data storage infrastructure
• Staff training on data security and privacy obligations

While we apply robust security practices, no online platform can guarantee absolute security. We encourage you to use a strong, unique password for your zs444 account and to enable any available two-factor authentication features.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and any applicable regulatory authority as required by law, without undue delay.

We reserve the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The revised Policy will be published on this page with an updated effective date.

Where changes are material, we will make reasonable efforts to notify registered users via on-screen notification or email prior to the changes taking effect. Continued use of the Services following publication of a revised Policy constitutes your acceptance of those revisions.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact our support team using the following details:

• Support Email (plain text — not a clickable link): [email protected]
• Live Chat: Available via the on-site chat widget as indicated on the Platform.
• Support Languages: English and Urdu.
• Response Time: We aim to acknowledge data subject requests within a reasonable timeframe and to respond fully within 30 days, subject to the complexity of the request.

If you are not satisfied with our response to a data protection concern, you may have the right to lodge a complaint with the relevant supervisory authority in the jurisdiction governing this Policy. Please contact our support team for further guidance on applicable supervisory bodies.