Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is published by ZCC77 ("ZCC77", "we", "us" or "our") and applies to all personal data collected, processed and stored in connection with your use of the online gaming and sports betting platform accessible at https://zcc77.cam (the "Platform").

ZCC77 is committed to protecting the privacy and personal data of all players, visitors and users of the Platform in accordance with applicable data protection principles. This Policy describes our data-handling practices in plain language so that you can make informed decisions about your personal information.

By registering an account, accessing the Platform or submitting personal information through any part of the Website, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should not use the Platform.

2. Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, postal address, date of birth, financial details and government-issued identity document numbers.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, ZCC77.
• "Data Processor" means any third party that processes Personal Data on behalf of ZCC77 under a data processing agreement.
• "KYC" means Know Your Customer — the identity and payment verification process.
• "Cookie" means a small text file placed on your device by the Platform for the purposes described in Section 11.
• "AML" means Anti-Money Laundering — legal obligations requiring financial and gaming operators to monitor, record and report certain transactions and customer activities.
• "Player" / "User" / "you" means any individual who accesses, browses or uses the Platform, whether registered or unregistered.

3. Data Controller

ZCC77 acts as the Data Controller in respect of Personal Data collected through the Platform. As Data Controller, ZCC77 is responsible for determining the purposes for which and the manner in which your Personal Data is processed.

Queries, requests and complaints relating to the processing of your Personal Data should be directed to the ZCC77 Data Protection contact using the details in Section 15 of this Policy.

4. Data We Collect

4.1 Registration Data

When you create an account on ZCC77, we collect the following information:

• Full legal name;
• Date of birth;
• Residential address (including city — such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar — and country);
• Email address;
• Mobile phone number;
• Username and encrypted password.

4.2 Identity Verification (KYC) Data

To comply with AML obligations and to verify player eligibility, we may collect:

• Government-issued identity document (CNIC, passport or national identity card) — including the document number, name and date of birth as shown;
• Proof of address documentation;
• Photographic identification or selfie image for liveness verification;
• Proof of payment method (e.g., a screenshot of an Easypaisa or JazzCash account header, a bank statement header showing your name and account number — not full statements unless required by an AML review).

4.3 Transaction and Financial Data

We collect records of all financial transactions conducted through the Platform, including deposit amounts, withdrawal requests, payment method references (wallet identifiers, partial IBAN or bank account references), transaction timestamps and currency. We do not store full payment card numbers or full bank account numbers on our servers — these are handled by our payment service providers using their own PCI-compliant systems.

4.4 Gaming and Betting Activity Data

We collect records of all wagering and gaming activity including game sessions, bet amounts, outcomes, responsible gambling limit settings and self-exclusion history. This data is used for account management, regulatory compliance, dispute resolution and responsible gambling monitoring.

4.5 Technical and Usage Data

When you use the Platform, we automatically collect:

• IP address and approximate geolocation;
• Device type, operating system and browser version;
• Session timestamps, pages visited and features used;
• Referring URL and exit page;
• Error and crash logs.

4.6 Communications Data

If you contact our support team via live chat, email or any other channel, we retain records of those communications — including the content of messages and support tickets — for the purpose of resolving queries, training, quality assurance and record-keeping.

5. Purposes of Processing & Legal Basis

The table below sets out the purposes for which we process your Personal Data and the legal basis on which that processing is conducted.

6. Sharing Your Personal Data

6.1 Service Providers and Data Processors

ZCC77 engages third-party service providers who process Personal Data on our behalf under contractual data processing agreements. Categories of such providers include:

• Payment processors: Entities that handle deposit and withdrawal processing. In a Pakistani context, players should note that payment services familiar to local users — such as Easypaisa, JazzCash, Raast, or banking services at HBL, UBL, Meezan Bank or Bank Alfalah — operate under their own privacy policies and data-handling frameworks. ZCC77 shares only the transaction data necessary to complete a payment. These providers do not endorse or affiliate with ZCC77.
• KYC and identity verification providers: Third-party services that assist with document verification and liveness checks.
• Cloud infrastructure and hosting providers: Entities that provide the servers, databases and content delivery infrastructure on which the Platform operates.
• Fraud prevention and AML screening services: Tools used to detect and prevent financial crime.
• Analytics platforms: Services used to understand Platform usage and improve the user experience.

6.2 Legal and Regulatory Disclosures

ZCC77 may disclose Personal Data to law enforcement, regulatory authorities or other government bodies where we are legally required to do so, where we have a good-faith belief that disclosure is necessary to comply with a legal obligation, or where disclosure is necessary to protect the rights, property or safety of ZCC77, its players or the public.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets or other corporate restructuring, Personal Data held by ZCC77 may be transferred to the successor entity as part of that transaction. Players will be notified of any such transfer via a notice on the Platform or by email, and the successor entity will be required to honour this Policy or provide equivalent protections.

6.4 No Sale of Data

ZCC77 does not sell, rent, trade or otherwise provide your Personal Data to third parties for their own commercial or marketing purposes. This is an unconditional commitment.

7. International Data Transfers

ZCC77 and its service providers may process Personal Data in countries outside of the jurisdiction where you reside. Where data is transferred internationally, ZCC77 takes appropriate steps to ensure that adequate protections are in place, including the use of contractual safeguards with Data Processors to ensure a comparable level of data protection.

Pakistani players should note that Pakistan does not currently have an adequacy decision from major data protection authorities in the European Union or the United Kingdom. Cross-border data flows involving your Personal Data are conducted on the basis of ZCC77's standard contractual arrangements with service providers.

8. Data Retention

ZCC77 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, as described in Section 5, or as required by applicable legal obligations. The following indicative retention periods apply:

• Account registration data: Retained for the duration of the active account relationship and for a minimum period of five (5) years following account closure, as required for AML and record-keeping compliance.
• KYC documentation: Retained for a minimum of five (5) years following the completion of the KYC process or the date of the last transaction, whichever is later.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity records: Retained for the duration of the account relationship and for a period of five (5) years thereafter.
• Customer support communications: Retained for a period of three (3) years from the date of the last communication in a support ticket.
• Technical and usage data: Typically retained in aggregate or anonymised form for up to twenty-four (24) months for analytics purposes.

9. Your Rights Over Your Personal Data

Subject to applicable law and the conditions set out in this Policy, you have the following rights in relation to your Personal Data held by ZCC77. These rights may be subject to limitations where legal obligations (such as AML record-keeping requirements) override individual data subject rights.

10. Security Measures

ZCC77 implements industry-standard technical and organisational measures to protect your Personal Data against unauthorised access, alteration, disclosure, loss or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your browser or device and the Platform;
• Encryption at rest for sensitive data stored on ZCC77 servers;
• Access controls — Personal Data is accessible only to authorised employees and contractors on a need-to-know basis;
• Password hashing — account passwords are stored using one-way cryptographic hashing, meaning no ZCC77 employee can read your password in plain text;
• Two-factor authentication (2FA) options available to all registered users;
• Regular security assessments of Platform infrastructure and code;
• Incident response procedures to detect, contain and respond to data security incidents.

Despite these measures, no data transmission over the internet or method of electronic storage can be guaranteed 100% secure. ZCC77 cannot accept liability for breaches that are beyond its reasonable control. If you believe your account has been compromised, contact us immediately at [email protected].

11. Cookies & Similar Technologies

11.1 What Are Cookies?

Cookies are small text files placed on your device by the Platform when you visit. They serve various functions — from keeping you logged in to analysing how the Platform is used. Similar technologies include local storage, session storage and pixel tags.

11.2 Types of Cookies We Use

11.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse all or specific types of cookies. Please note that disabling strictly necessary cookies may affect the functionality of the Platform — certain features may not operate correctly if essential cookies are blocked. Marketing cookies are only activated with your consent and can be withdrawn at any time through your browser or Account preferences.

12. Minors and Age Restriction

The ZCC77 Platform is strictly intended for adults aged 18 years or over, or the higher minimum age required by applicable law or the operator's license jurisdiction. ZCC77 does not knowingly collect Personal Data from persons under the minimum age. If you have reason to believe that a minor has provided Personal Data to ZCC77, please contact us immediately at [email protected] and we will take steps to delete that data and close any associated account.

13. Third-Party Links and Services

The Platform may contain references to third-party services — for example, payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah are mentioned for contextual reference regarding familiar Pakistani payment rails. These references are informational only; ZCC77 has no control over the privacy practices of these third parties. Each provider operates under its own privacy policy. Players should review the relevant provider's privacy documentation before initiating any transaction through that service.

ZCC77 is not responsible for the content, privacy practices or security of any third-party service. The mention of any provider or institution does not constitute an endorsement by that provider of ZCC77 or any gambling activity.

14. Changes to This Privacy Policy

ZCC77 reserves the right to update or revise this Privacy Policy at any time. When material changes are made, we will notify registered Players by email or via a prominent notice on the Platform prior to the changes taking effect. The effective date at the top of this page will be updated to reflect the date of the most recent revision.

Your continued use of the Platform following the publication of changes constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how we protect your Personal Data.

15. Contact Us & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a complaint about the way ZCC77 has handled your Personal Data, please contact us using the details below:

We aim to acknowledge all data-related requests within 5 business days and to provide a substantive response within 30 days. For complex requests this period may be extended by up to a further 30 days, in which case we will notify you of the extension and the reason for it.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in the jurisdiction under whose laws ZCC77 is licensed or incorporated.