Privacy Policy — ZT999

This Privacy Policy ("Policy") is published by ZT999 ("we", "us", "our", "the Platform"), the operator of the website accessible at https://zt999.cam. It describes how ZT999 collects, processes, stores and shares personal data relating to users ("you", "your") who access or register on the Platform.

ZT999 is an English-language online gaming information platform serving the Pakistani market and other jurisdictions where access is lawfully permitted. We are committed to protecting the privacy and security of the personal data entrusted to us and to complying with applicable data protection obligations.

This Policy should be read alongside our Terms & Conditions, which govern the general use of the Platform. By accessing or using ZT999, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with this Policy, you must cease using the Platform.

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

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, email address, date of birth, financial information and device identifiers.
• "Processing" — Any operation performed on personal data, including collection, storage, use, disclosure, transfer or deletion.
• "Data Controller" — The entity that determines the purposes and means of processing personal data — in this context, ZT999.
• "Data Processor" — A third party that processes personal data on behalf of the Data Controller under a contractual obligation.
• "KYC" — Know Your Customer — the identity verification process used to confirm user identity for regulatory, anti-money laundering and responsible gambling purposes.
• "Cookies" — Small text files stored on your device by the Platform to support session management, analytics and user experience.
• "Special Category Data" — Sensitive personal data requiring heightened protection, including health data, biometric data and data relating to gambling behaviour where it reveals vulnerability.
• "Third Party" — Any entity other than you and ZT999 that processes personal data in connection with the Platform's services.

ZT999 collects personal data through a variety of means, including direct submission by you during registration and ongoing account use, automated collection through your device and browser, and third-party sources such as KYC verification partners and payment processors.

The categories of personal data we collect are set out in the table below:

We do not intentionally collect Special Category Data unless required for responsible gambling assessments (e.g., self-exclusion records or affordability checks) or as mandated by applicable law. We do not collect biometric data.

ZT999 processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil the Terms and Conditions you have accepted, including account management, transaction processing and service delivery.
• Legal Obligation: Processing required to comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), KYC, responsible gambling and other regulatory requirements.
• Legitimate Interests: Processing in pursuit of ZT999's legitimate business interests, including fraud prevention, security monitoring, Platform improvement and abuse detection, where such interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent for specific processing activities (such as certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

ZT999 uses the personal data it collects for the following purposes:

To create, verify and manage your account; to process deposits and withdrawals; to deliver the gaming, betting and live casino services you access through the Platform; and to handle your customer support requests.

To verify your identity, age and address as required by applicable regulations; to conduct source of funds checks where required; and to satisfy anti-money laundering and counter-terrorism financing obligations.

To monitor account activity for indicators of problem gambling; to apply deposit limits, session time limits, loss limits and self-exclusion restrictions at your request or as required by regulatory obligations; and to provide responsible gambling resources and interventions.

To detect, investigate and prevent fraudulent transactions, bonus abuse, multi-accounting, money laundering and other prohibited conduct; to protect the security of the Platform and all users; and to investigate and report suspected criminal activity where required by law.

To send transactional communications relating to your account, including deposit confirmations, withdrawal updates, KYC requests and account security alerts. Where you have provided consent, to send promotional communications about bonuses, new game launches or Platform updates. You may opt out of promotional communications at any time.

To analyse aggregated usage data to understand how users interact with the Platform; to improve navigation, performance and content; and to develop new features and services. Analytics data is processed in aggregated or pseudonymised form where possible.

ZT999 does not sell, rent or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary and proportionate:

Third-party vendors engaged to provide services in support of the Platform, including KYC verification providers, payment processors, cloud hosting providers, IT security providers and customer support software providers. All such processors are engaged under data processing agreements that restrict their use of your data to the provision of services on ZT999's behalf.

Payment transaction data is shared with the relevant payment processing partner when you make a deposit or withdrawal. Familiar payment references for Pakistani users include Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah. These are referenced as contextual examples only. None of these providers are affiliated with or endorse ZT999. Any payment processing arrangements are separate commercial relationships, and data sharing is limited to what is required to complete your requested transaction.

Where required by applicable law, court order or instruction from a competent authority, ZT999 may disclose personal data to regulatory bodies, law enforcement agencies or other public authorities. We will always seek legal review before disclosing data in response to government requests unless prevented by law from doing so.

In the event of a merger, acquisition, restructuring or sale of all or part of ZT999's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and your rights in relation to it prior to the transfer taking effect where required by applicable law.

As an internationally operating platform, ZT999 may transfer your personal data to countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. This may include transfers to the jurisdiction in which the Operator or its service providers are incorporated or host their infrastructure.

Where such transfers take place, ZT999 takes reasonable steps to ensure that your personal data is protected by appropriate safeguards, which may include contractual data transfer mechanisms, standard data protection clauses or equivalent protections recognised in the recipient jurisdiction.

Pakistani users should be aware that data transferred internationally may be subject to the laws of the recipient country, which may differ from Pakistani law. If you have questions about international transfers of your data, please contact us using the details in Section 13.

ZT999 retains personal data for as long as is necessary to fulfil the purposes described in this Policy, unless a longer retention period is required by applicable law or regulatory obligation. The following general principles apply to our retention practices:

• Active Accounts: Personal data is retained for the duration of your account relationship with ZT999 and is kept reasonably up to date at your request.
• Closed Accounts: Following account closure, ZT999 retains identity, financial and KYC data for a minimum of five (5) years to satisfy anti-money laundering record-keeping requirements. This period may be extended where required by applicable law or ongoing legal proceedings.
• Self-Excluded Users: Self-exclusion records and associated account data are retained for the duration of the self-exclusion period and thereafter as required to prevent re-registration.
• Support Communications: Customer support correspondence is retained for a reasonable period to maintain a record of dispute resolution and service history.
• Marketing Data: Where consent-based marketing lists are maintained, data is retained until you withdraw consent or the data is no longer required for the stated purpose.

When retention periods expire, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures. If you wish to request deletion of your data before the applicable retention period expires, please see Section 11 (Your Rights).

ZT999 uses cookies and similar tracking technologies (such as web beacons and local storage objects) to support Platform functionality, maintain session security, analyse usage patterns and improve user experience. By continuing to use the Platform, you consent to our use of cookies in accordance with this section.

• Essential / Strictly Necessary Cookies: Required for the Platform to function correctly, including session authentication, security tokens and load balancing. These cannot be disabled without significantly impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game category selections and responsible gambling tool configurations to improve your experience on return visits.
• Analytics Cookies: Collect aggregated information about how users navigate and interact with the Platform to help us understand usage patterns and improve content, performance and navigation.
• Security Cookies: Detect and prevent fraudulent activity, bot access and security threats by analysing access patterns and flagging anomalous behaviour.

You can manage and control cookie settings through your browser preferences. Most modern browsers allow you to block or delete cookies, though doing so may affect the functionality of the Platform. For device-level cookie management on mobile, refer to your device operating system's privacy settings.

ZT999 does not currently use advertising network cookies or third-party behavioural advertising technologies on the Platform.

ZT999 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include but are not limited to:

• SSL/TLS encryption for all data transmitted between your device and the Platform
• Password hashing using industry-standard cryptographic algorithms — we do not store passwords in plain text
• Role-based access controls restricting staff access to personal data on a need-to-know basis
• Regular security assessments and vulnerability testing of Platform infrastructure
• Intrusion detection and monitoring systems to identify and respond to security incidents
• Data processing agreements with all third-party processors imposing equivalent security standards

While we take robust measures to protect your data, no internet-based system is completely immune from security risks. You are responsible for maintaining the security of your own account credentials and for notifying us immediately if you suspect unauthorised access. Users in cities like Karachi, Lahore, Islamabad and across Pakistan are encouraged to use strong, unique passwords and to enable any additional security options available in their account settings.

Subject to applicable law and any overriding legal obligations (such as AML record-keeping requirements), you have the following rights in relation to your personal data held by ZT999. To exercise any of these rights, please contact us using the details in Section 13.

ZT999 will respond to all valid data rights requests within a reasonable timeframe. We may need to verify your identity before processing a request to protect against fraudulent or unauthorised requests. We will not charge a fee for exercising your rights unless requests are manifestly unfounded, excessive or repetitive.

ZT999 is strictly intended for adults aged 18 years and over, or the higher minimum age required by the operator's licence jurisdiction. We do not knowingly collect personal data from individuals below the required minimum age.

As part of our KYC process, we verify the age of all registered users. Where we discover or have reasonable grounds to suspect that personal data has been collected from a minor, we will promptly close the associated account, void any transactions associated with it, and securely delete the data subject to any legal obligations to retain records of the incident.

Account holders who are parents or guardians are responsible for ensuring that minors in their household do not gain access to the Platform. We strongly recommend the use of parental control software. If you believe a minor has registered an account, contact our support team immediately.

If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by ZT999, please contact our Data Privacy team using the details below. Do not include sensitive personal data or full financial account numbers in your initial correspondence.

If you are not satisfied with our response to your privacy complaint, you have the right to escalate the matter to the competent supervisory authority in the jurisdiction in which the Operator is licensed.

ZT999 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory guidance or operational circumstances. When material changes are made to this Policy, we will:

• Update the "Last Updated" date at the top of this page
• Display an on-screen notice to registered users upon next login where the changes are material
• Send an email notification to your registered email address where changes significantly affect your rights or our processing activities

Your continued use of the ZT999 Platform following the publication of an amended Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the amended Policy, you must cease using the Platform and close your account. We recommend reviewing this Policy periodically to stay informed of our current data practices.