Privacy Policy

ZH98 ("we", "us", "our", or "the Operator") is the operator of the online entertainment platform located at https://zh98.cam (the "Platform"). This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

We are committed to protecting and respecting your privacy. This Policy explains what personal data we collect, the purposes for which we process it, the legal basis on which we rely to do so, how long we retain it, and the rights you have in relation to your personal data.

This Policy applies to all users of the Platform, including visitors who have not registered an account and registered users who are actively using our services. It applies to data collected through the Platform, through our customer support channels, and through any other interaction you have with ZH98.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which form part of the overall agreement between you and ZH98.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data or an online identifier.
• "Processing" means any operation or set of operations performed on personal data, including collection, recording, organisation, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure or destruction.
• "Controller" means the entity that determines the purposes and means of the processing of personal data. ZH98 is the data controller in respect of your personal data.
• "Processor" means a natural or legal person that processes personal data on behalf of the controller.
• "Data Subject" means the natural person to whom personal data relates — in this context, you as the user of the Platform.
• "Consent" means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they signify agreement to the processing of personal data relating to them.
• "KYC" means Know Your Customer — the identity and age verification procedures undertaken by the operator.
• "Cookies" means small text files stored on your device by a website that are used to remember information about your visit, preferences and browsing behaviour.

ZH98 collects and processes the following categories of personal data:

Identity Data

• Full legal name, date of birth, gender and nationality;
• Copies of government-issued identification documents provided during KYC verification (e.g., national identity card, passport, driver's licence);
• Selfie or facial image where required for identity verification purposes.

Contact Data

• Email address and mobile phone number;
• Residential address and postal code;
• City of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar).

Account & Financial Data

• Username, encrypted password and account reference number;
• Deposit and withdrawal history, account balance and transaction records;
• Payment method details as required for processing transactions and anti-money laundering compliance;
• Source of funds information where applicable thresholds are triggered.

Technical & Usage Data

• IP address, device type, browser type and version, operating system;
• Pages visited, session duration, click-stream data and referring URLs;
• Geolocation data derived from your IP address;
• Log files and platform interaction records.

Responsible Gambling Data

• Self-imposed limits, cool-off periods and self-exclusion elections;
• Responsible gambling assessment responses where voluntarily provided.

Communications Data

• Records of your correspondence with our customer support team via live chat or email;
• Survey responses and feedback submissions.

We collect your personal data through the following means:

ZH98 processes your personal data only where a valid lawful basis exists. The lawful bases we rely on are as follows:

Where we rely on legitimate interests as our lawful basis, we have assessed that those interests are not overridden by your rights and freedoms as a data subject. You may request further information about this balancing assessment by contacting us at [email protected].

ZH98 uses the personal data we collect for the following purposes:

• Account Services: To register and maintain your account, verify your identity, process your transactions and provide access to the Platform's features;
• Legal & Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering, counter-terrorism financing, age verification and responsible gambling regulations;
• Customer Support: To respond to your enquiries, complaints and support requests and to maintain records of those interactions;
• Security & Fraud Prevention: To detect, investigate and prevent fraudulent transactions, account takeovers, multi-accounting and other prohibited conduct;
• Responsible Gambling: To monitor account activity for signs of problem gambling and to action your responsible gambling tool elections (deposit limits, self-exclusion, etc.);
• Platform Improvement: To analyse usage patterns, diagnose technical issues and improve the performance, design and content of the Platform;
• Marketing (with consent): To send you promotional communications about ZH98 offers, new features and events where you have opted in to receive such communications. You may withdraw consent at any time;
• Legal Claims: To establish, exercise or defend legal claims where necessary.

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first informing you and, where required, obtaining your consent.

ZH98 uses cookies and similar tracking technologies to enhance your experience on the Platform, to understand how the Platform is used, and to support security and fraud prevention functions.

The categories of cookies we use are as follows:

• Essential Strictly Necessary Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in, security tokens and load-balancing cookies. These cannot be disabled without impairing core Platform functionality.
• Functional Functional Cookies: Remember your preferences such as language settings, display preferences and previously entered information to improve your experience across sessions.
• Analytics Analytics Cookies: Collect aggregated, anonymised data about how visitors use the Platform — pages visited, session lengths, click paths and error events — to help us improve the Platform.
• Marketing Marketing Cookies: Used, with your consent, to track your activity across sessions and deliver relevant promotional content. These are only placed where you have opted in via our cookie consent mechanism.

Non-essential cookies (functional, analytics and marketing) are only placed on your device where you have provided consent via the cookie consent tool displayed on your first visit. You may withdraw or adjust your cookie preferences at any time through your account settings or browser controls.

Please note that disabling certain cookies may affect the functionality of the Platform and your user experience.

ZH98 does not sell, rent or trade your personal data to third parties for their own marketing or commercial purposes. We share personal data only in the following circumstances and only to the extent necessary:

• Service Providers & Processors: Third-party companies that provide services on our behalf, including payment processors, identity verification providers, fraud detection services, data hosting and infrastructure providers, customer support platforms and email delivery services. These providers process your data only on our documented instructions;
• Regulatory Authorities: We may disclose personal data to licensing authorities, financial intelligence units, law enforcement agencies or other governmental bodies where required to do so by law or where we believe disclosure is necessary to prevent serious harm or illegal activity;
• Legal Proceedings: Where necessary to establish, exercise or defend legal claims, we may share personal data with legal advisors, courts or dispute resolution bodies;
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets, your personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections;
• Responsible Gambling Bodies: Where self-exclusion schemes or multi-operator exclusion registers are in operation and you have enrolled in such a scheme, relevant data may be shared with the scheme operator.

All third-party processors are subject to appropriate contractual data processing obligations and are required to implement adequate security measures to protect your personal data.

ZH98 is an internationally operated platform. In the course of providing our services, your personal data may be transferred to, and processed in, countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data. These safeguards may include:

• Standard contractual clauses approved by a relevant data protection authority;
• Binding corporate rules where applicable;
• Reliance on an adequacy decision in respect of the destination country;
• Other lawful transfer mechanisms recognised under applicable data protection law.

By using the Platform, you acknowledge that your personal data may be processed in countries outside Pakistan. If you have questions about the specific safeguards in place for any particular transfer, please contact us at [email protected].

ZH98 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering and know-your-customer record-keeping obligations;
• Transaction records: Retained for a minimum of five (5) years following the date of each transaction;
• Customer support communications: Retained for a minimum of three (3) years from the date of the interaction;
• Marketing consent records: Retained until consent is withdrawn, plus a reasonable period thereafter to evidence the consent history;
• Technical and usage logs: Retained for up to twelve (12) months, after which they are anonymised or deleted.

Where we no longer have a lawful basis to retain personal data, we will securely delete or anonymise it. Please note that certain data may be retained for longer periods where required by applicable law or where necessary in connection with ongoing legal proceedings.

Subject to applicable law and certain exceptions, you have the following rights in relation to your personal data held by ZH98:

To exercise any of the above rights, please contact our support team via live chat or by email at [email protected]. We will respond to all verified requests within a reasonable period and in accordance with applicable legal requirements. We may need to verify your identity before processing a request.

Please be aware that certain rights are subject to limitations. For example, we may be required to retain transaction data beyond the period you request erasure in order to comply with anti-money laundering record-keeping obligations.

ZH98 implements appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. Our security measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data fields — including passwords, payment details and identity documents — at rest;
• Role-based access controls ensuring that only authorised personnel have access to personal data on a need-to-know basis;
• Regular security assessments, penetration testing and vulnerability management procedures;
• Incident response procedures enabling us to detect, contain and report personal data breaches in a timely manner.

While we take all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly if you suspect any unauthorised access to your account.

The Platform may contain references to third-party content or services. ZH98 does not control those third parties and is not responsible for their privacy practices. This Privacy Policy applies only to data processed by ZH98 in connection with your use of the Platform.

We encourage you to review the privacy policies of any third-party services before submitting personal data to them. The inclusion of a reference to any third-party name or service on the Platform does not constitute an endorsement of that party or its privacy practices.

ZH98 is strictly an adults-only platform. We do not knowingly collect personal data from individuals under 18 years of age, or below the minimum age required by the operator's licence jurisdiction, whichever is higher.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. Account holders are responsible for ensuring that minors in their household do not access the Platform or provide personal data through it.

If you believe that a minor has registered an account or provided personal data through the Platform, please contact us immediately at [email protected].

ZH98 is an English-language platform targeting users who choose to access it from Pakistan and elsewhere. We do not represent that our data processing practices are governed by or compliant with any specific Pakistani data protection legislation. Pakistani users access and use the Platform at their own risk and under their own legal responsibility.

Payment method names that may be familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are referenced on this Platform for contextual familiarity only. Their mention in this Privacy Policy or elsewhere on the Platform does not imply that these providers endorse ZH98, support gambling transactions or have any affiliation with the Operator.

ZH98 does not share your personal data with any Pakistani government authority, financial regulator or payment provider unless compelled to do so by a valid legal order from a competent authority with jurisdiction over the Operator.

This Privacy Policy does not constitute legal advice. If you have concerns about the privacy implications of using an offshore online gambling platform under Pakistani law, we recommend that you seek independent legal advice before registering.

ZH98 reserves the right to update or amend this Privacy Policy at any time. The revised Policy will be posted on this page with an updated effective date . Where we make material changes to the way we process your personal data, we will provide prominent notice — such as an on-site banner or an email to your registered address — prior to the changes taking effect.

Your continued use of the Platform following the posting of any amended Privacy Policy constitutes your acceptance of the changes. If you do not agree with any amendment, you should cease using the Platform and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically to stay informed about how ZH98 protects your personal data.

If you have any questions, concerns or requests relating to this Privacy Policy or the way ZH98 processes your personal data, please contact our support team through any of the following channels:

• Live Chat: Available 24/7 directly through the Platform;
• Email: [email protected] (plain text — not a clickable link).

We aim to acknowledge all privacy-related enquiries within two (2) business days and to provide a substantive response within thirty (30) days of receipt, subject to the complexity of the request and any identity verification requirements.

For data subject rights requests, please include your registered username and a description of the right you wish to exercise. We may need to verify your identity before actioning your request to protect the security of your account and personal data.