ZC Game Privacy Policy – How We Handle Your Personal Data in Pakistan

ZC Game is the data controller for all personal information collected through the zcgame.app platform and any associated applications. As data controller, ZC Game determines the purposes for which your personal data is processed and the manner in which that processing is carried out.

Our platform is operated and maintained by the ZC Game team. All data-related correspondence can be directed to support@zcgame.app. For data-specific requests including access, deletion or correction requests, use the subject line "Privacy Request" when contacting us so that our data team receives your message directly.

ZC Game operates primarily to serve players in Pakistan. Our platform and data practices are designed with the needs and expectations of Pakistani players in mind, while adhering to the data protection standards of our operating jurisdiction.

ZC Game collects only the personal data that is genuinely necessary to provide you with a safe, functional and fair gaming experience. The categories of data we collect are listed in the table below:

Every piece of data ZC Game collects serves a specific, defined purpose. We do not collect data speculatively or for purposes we haven't identified. The main reasons we hold your data are:

• Account management: Creating and maintaining your ZC Game account, verifying your identity and enabling secure login.
• Payment processing: Facilitating your PKR deposits and withdrawals through Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT and card payments.
• Regulatory compliance: Meeting our obligations under anti-money laundering (AML) rules, Know Your Customer (KYC) requirements and age verification standards.
• Fraud prevention and security: Detecting and preventing fraudulent accounts, unauthorised access and payment fraud.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and enforcing the limits you set on your own account.
• Platform improvement: Analysing aggregated, anonymised usage data to improve our games, interface and service performance.
• Customer support: Resolving complaints, answering questions and maintaining records of your support history so we can assist you more effectively.
• Marketing communications: Sending you information about promotions, bonuses and new games at ZC Game – only where you have given explicit consent to receive such communications and subject to your marketing preferences.

ZC Game does not use your personal data to make fully automated decisions that have significant legal or equivalent effects on you without human oversight.

ZC Game processes your personal data under one or more of the following legal grounds, depending on the specific processing activity:

• Contract performance: Processing that is necessary to deliver the services you signed up for – your account, gaming access and payment processing all fall under this basis.
• Legal obligation: Processing required by law, including AML compliance, KYC verification and age verification obligations placed on licensed gaming operators.
• Legitimate interests: Processing that serves ZC Game's legitimate business interests, such as fraud prevention, security monitoring and platform analytics, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where neither contract performance, legal obligation nor legitimate interest provides a valid basis – for example, for optional marketing communications – ZC Game relies on your freely given, specific and informed consent. You can withdraw consent at any time from your account settings or by contacting support.

ZC Game never sells your personal data to third parties. We do not share your data with advertisers, data brokers or any other organisations for their own commercial purposes. Your data may be shared with the following categories of recipient, strictly as necessary:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT processors and card payment networks receive the minimum data required to process your transactions. These providers operate under their own privacy policies and applicable Pakistani financial regulations.
• Identity verification services: Third-party KYC providers who assist in verifying identity documents and age. These providers are contractually prohibited from using your data for any purpose other than verification for ZC Game.
• Game software providers: Pragmatic Play, Play'n GO, NetEnt, Microgaming and other certified game studios may receive anonymised session identifiers required for game functionality. They do not receive your full identity or payment data.
• Regulatory and law enforcement authorities: ZC Game will share data with competent authorities where required by law, such as in response to a court order, AML investigation or fraud report. We will notify you of such disclosures where legally permitted to do so.
• Technical service providers: Cloud hosting, analytics and security service providers who assist ZC Game in running the platform. These providers act as data processors under ZC Game's instructions and are bound by data processing agreements.

All third parties with whom ZC Game shares personal data are required to implement appropriate security measures and to handle your data in accordance with applicable privacy standards.

ZC Game uses a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration or destruction:

• SSL/TLS encryption: All data transmitted between your device and ZC Game servers is encrypted using industry-standard TLS 1.2 or higher. You can verify this by the padlock icon in your browser address bar when on zcgame.app.
• Data encryption at rest: Personal data stored on ZC Game servers is encrypted. Payment data is handled through certified payment processors and is never stored on ZC Game servers in its raw form.
• Access controls: Access to player data within ZC Game's operations is restricted on a strict need-to-know basis. Staff members can only access the data necessary for their specific role. All access is logged and audited.
• Penetration testing: ZC Game's platform undergoes regular security testing by qualified third-party security professionals to identify and address vulnerabilities before they can be exploited.
• Incident response: ZC Game maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and the relevant regulatory authority within the timeframes required by applicable law.

No digital system can be guaranteed to be 100% secure. However, ZC Game commits to implementing the security measures described above and to responding to any incident promptly and transparently.

ZC Game retains personal data for as long as is necessary for the purposes described in this policy and no longer. The standard retention periods are:

• Active account data: Retained for the duration of your account plus five years following account closure. This covers the minimum period required by AML and regulatory record-keeping obligations.
• Transaction records: Financial transaction records are retained for seven years after the transaction date in line with standard financial record-keeping requirements.
• KYC documents: Identity verification documents are retained for five years after account closure. During that period they are stored in encrypted form accessible only to authorised compliance personnel.
• Support communications: Chat transcripts and email records are retained for three years after the last interaction to support any future dispute resolution.
• Technical/log data: Server logs and IP data are retained for up to 12 months for security monitoring and fraud detection purposes.
• Marketing consent records: Records of your marketing consent or opt-out are retained for as long as they remain relevant to our communications with you.

When data reaches the end of its retention period, it is securely deleted or irreversibly anonymised. Anonymised, aggregated data (from which no individual can be identified) may be retained indefinitely for statistical purposes.

ZC Game uses cookies and similar tracking technologies on zcgame.app. Cookies are small text files stored on your device by your browser when you visit a website. They help us deliver a working, personalised platform experience.

As a ZC Game player you have a set of rights over the personal data we hold about you. ZC Game will respond to all valid privacy rights requests within 30 days. Submit requests to support@zcgame.app with the subject line "Privacy Request".

ZC Game is strictly for players aged 18 years and over. We do not knowingly collect personal data from anyone under 18. Age verification is a core part of our registration and KYC processes and we take underage access extremely seriously.

If ZC Game discovers or receives a credible report that an account is held by a person under 18, that account will be immediately suspended. Any deposits made by an underage player will be returned (minus any processing costs already incurred) and all gaming activity on the account will be voided. Personal data collected in connection with an underage account will be deleted promptly after the investigation is complete, subject to any minimum retention obligations required by law.

If you are a parent or guardian and believe your child has registered at ZC Game, please contact us immediately at support@zcgame.app. We will investigate and take appropriate action as quickly as possible.

ZC Game may send you marketing communications about promotions, bonuses, new games and platform updates. We will only send you marketing messages if you have specifically opted in to receive them during registration or at a later point through your account settings.

You can opt out of marketing communications at any time. The easiest ways to do this are:

• Clicking the unsubscribe link at the bottom of any ZC Game marketing email.
• Updating your notification preferences in your account dashboard under Settings → Notifications.
• Contacting our support team and requesting removal from all marketing lists.

Opt-out requests are processed within 48 hours. Please note that opting out of marketing communications does not opt you out of transactional messages such as deposit confirmations, withdrawal notifications and security alerts – these are sent regardless of marketing preference as they relate directly to your account activity.

ZC Game will never send marketing communications to players who are in an active self-exclusion period. Marketing suppression during self-exclusion is a firm commitment, not a best-effort measure.

ZC Game will update this Privacy Policy from time to time as our practices change or as new legal requirements come into effect. When a material change is made – one that meaningfully affects how your data is collected or used – we will notify registered players by email or in-platform notification at least 7 days before the change takes effect.

The version number and "Last Updated" date at the top of this page always reflect the most recently published version. Minor clarifications, such as corrections to grammar or formatting, may be applied without advance notice.

Continued use of ZC Game after the effective date of an update to this policy constitutes acceptance of the updated terms. If you do not agree with an update, you may request account closure through our support team before the update takes effect.

For any question, concern or request related to this Privacy Policy or the personal data ZC Game holds about you, please reach out through any of the following channels:

• Email: support@zcgame.app – use the subject line "Privacy Request" for data rights matters
• Live Chat: Available 24/7 on zcgame.app – our team typically responds within 5 minutes

ZC Game commits to acknowledging all privacy requests within 5 business days and resolving them within 30 days. For complex requests that require more time, we will notify you of the extended timeline and the reason for the delay.

If you are not satisfied with our response to a privacy concern, you have the right to raise a complaint with the relevant data protection authority in your jurisdiction.