Privacy Policy — ZB22

ZB22 (hereinafter "ZB22", "we", "us" or "our") is the operator of the online gaming and sports betting platform accessible at zb22.cam. We are committed to protecting the privacy and personal data of all users (hereinafter "User", "you" or "your") who access our Platform.

This Privacy Policy (hereinafter "Policy") sets out, in clear and accessible terms, the categories of personal data we collect, the purposes for which that data is processed, the conditions under which it may be shared, the security measures we employ to protect it, and the rights available to you in relation to your data.

This Policy applies to all personal data collected through the ZB22 website, mobile-optimised pages, account registration flows, support communications and any other interaction you have with the ZB22 Platform. It should be read alongside our Terms & Conditions and Responsible Gambling Policy.

The following terms carry the meanings set out below throughout this Policy:

ZB22 collects Personal Data only to the extent necessary for the legitimate operation of the Platform and fulfilment of our legal and regulatory obligations. The categories of data we collect are as follows:

3.1 — Registration Data

3.2 — KYC / Identity Verification Data

3.3 — Financial Transaction Data

3.4 — Usage & Technical Data

3.5 — Communications Data

ZB22 processes your Personal Data on one or more of the following legal bases, depending on the nature of the data and the purpose of processing:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions — including account management, processing deposits and withdrawals in PKR, and settling bets.
• Legal Obligation: Processing required to comply with applicable legal requirements, including KYC identity verification, anti-money-laundering (AML) controls and regulatory reporting.
• Legitimate Interests: Processing necessary for ZB22's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, abuse detection and service improvement.
• Consent: Where you have provided specific, informed and freely given consent — for example, opting in to receive promotional communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

ZB22 uses the Personal Data it collects for the following specific purposes:

• To create, maintain and secure your Account on the ZB22 Platform;
• To verify your identity and age in accordance with our KYC obligations;
• To process deposits, withdrawals and financial transactions denominated in PKR;
• To enforce the Terms & Conditions and detect, investigate and prevent prohibited conduct including fraud, collusion and money laundering;
• To monitor gaming activity for responsible-gambling purposes, including detecting patterns consistent with problem gambling and applying Account limits or interventions where appropriate;
• To provide and improve customer support, including responding to queries, resolving disputes and maintaining support records;
• To personalise your experience on the Platform — for example, displaying relevant promotions or cricket and PSL betting markets aligned with your activity history;
• To send transactional and account-related notifications — such as deposit confirmations, withdrawal status updates and security alerts;
• To send promotional communications, where you have given your consent to receive them — you may opt out at any time;
• To meet our obligations under applicable law and regulatory requirements, and to respond to lawful requests from competent authorities.

ZB22 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share your data only in the following limited circumstances:

• Service Providers (Data Processors): Third-party companies engaged by ZB22 to perform services on our behalf — including payment processors, identity-verification providers, fraud-detection systems, IT infrastructure providers and customer-support platforms. These providers are bound by contractual data-processing agreements and may only use your data as directed by ZB22.
• Game Content Providers: Game studios whose titles are hosted on the ZB22 Platform may receive anonymised or pseudonymised session data required for game functionality and RNG integrity verification. No directly identifiable personal data is shared with game studios beyond what is technically necessary.
• Regulatory & Law Enforcement Authorities: Where required by a valid court order, regulatory directive or other lawful authority, ZB22 may disclose Personal Data to competent public bodies. ZB22 will, to the extent permitted by law, notify you of such a request.
• Business Transfers: In the event of a merger, acquisition or sale of all or substantially all of ZB22's assets, your Personal Data may be transferred as part of that transaction. You will be notified of any such transfer and any material change to the privacy terms governing your data.

ZB22 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations, whichever is the longer period.

In general terms, the following retention principles apply:

• Active Account Data: Retained for the duration of your Account's active status and for a defined period following Account closure, as required for legal, regulatory and dispute-resolution purposes;
• KYC & Identity Documents: Retained for the minimum period required by applicable AML legislation governing the operator's license jurisdiction, typically a minimum of five years from the date of last transaction;
• Financial Transaction Records: Retained for the period required under applicable financial regulation, typically five to seven years;
• Support Communications: Retained for a period sufficient to resolve any outstanding disputes and maintain an audit trail, after which they are deleted or anonymised.

Upon expiry of applicable retention periods, Personal Data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identified individual.

ZB22 implements appropriate technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Transport Layer Security (TLS/HTTPS) encryption for all data transmitted between your device and the ZB22 Platform;
• Encryption of sensitive data at rest using industry-standard cryptographic algorithms;
• Access controls limiting Personal Data access to authorised ZB22 personnel on a need-to-know basis;
• Regular security reviews and vulnerability assessments of the Platform infrastructure;
• Password hashing — ZB22 does not store your password in plain text at any point.

While ZB22 takes security seriously, no system is entirely immune to risk. In the event of a Personal Data breach that poses a material risk to affected Users, ZB22 will take appropriate steps to contain the breach and notify affected Users in accordance with applicable law.

ZB22 uses cookies and similar tracking technologies to operate the Platform effectively, maintain session security and understand how users interact with our pages. Cookies are small text files placed on your device by your web browser when you visit the Platform.

The following categories of cookies may be used on the ZB22 Platform:

• Strictly Necessary Cookies: Essential for core Platform functionality — including maintaining your logged-in session, remembering account preferences and processing transactions. These cannot be disabled without impairing basic Platform operation.
• Performance & Analytics Cookies: Used to collect anonymised information about how users navigate the Platform, which pages are visited most frequently and how load times are performing. This data helps ZB22 improve the mobile experience for users across Pakistan.
• Functionality Cookies: Allow the Platform to remember your preferences, such as your preferred language display and display currency (PKR), so you do not need to re-enter them each session.
• Preference & Session Cookies: Short-lived cookies that expire when you close your browser, used to maintain your session state and deliver a consistent experience during a single visit.

You may manage cookie preferences through your browser settings. Disabling certain cookie categories may affect Platform functionality. ZB22 does not use cookies to track your browsing activity on external third-party websites.

ZB22 operates a global platform and may use service providers whose infrastructure is located in jurisdictions outside Pakistan. As a result, your Personal Data may be transferred to and processed in countries other than the country from which you access the Platform.

Where such international transfers occur, ZB22 ensures that appropriate safeguards are in place to protect your data, including contractual obligations on recipient service providers to maintain data-protection standards consistent with this Policy and applicable law.

By using the ZB22 Platform, you acknowledge that your Personal Data may be transferred internationally in accordance with the terms of this Policy.

Depending on your jurisdiction and the applicable data-protection framework, you may hold some or all of the following rights in relation to your Personal Data held by ZB22. We will respond to valid requests within a reasonable timeframe.

To exercise any of these rights, please contact ZB22 via live chat within your Account dashboard or by email at the address provided in Section 14 below. We may need to verify your identity before processing your request. We will respond within a reasonable period and, where applicable, within any timeframe required by law.

The ZB22 Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. ZB22 does not knowingly collect Personal Data from individuals below the minimum eligible age.

Where ZB22 discovers or has reasonable grounds to believe that Personal Data has been collected from an individual below the minimum eligible age, we will take immediate steps to close the Account, delete the associated data and, where deposits were made, return funds to the source payment method in accordance with applicable requirements.

If you believe a minor has registered on the ZB22 Platform, please contact our support team immediately so that appropriate action can be taken without delay.

ZB22 reserves the right to amend this Privacy Policy at any time. Where changes are material — for example, where we introduce a new category of data collection, a new processing purpose or a new category of recipient — we will provide advance notice to active Users via the Platform interface or by email to the address registered with your Account, with a reasonable period before the changes take effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the ZB22 Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

If you have questions or concerns about this Privacy Policy, wish to exercise any of your data-subject rights, or wish to make a complaint about how ZB22 handles your Personal Data, please contact us through the following channels:

We aim to acknowledge all privacy-related requests within a reasonable timeframe and resolve them as promptly as our obligations allow. For data-subject rights requests, we may need to verify your identity before proceeding.