ZD77 Privacy Policy

01 Introduction

ZD77 ("we", "us", "our") operates the online gaming information platform at https://zd77.cam (the "Platform"). This Privacy Policy explains how ZD77 collects, processes, stores, shares and protects personal data relating to individuals ("you", "the User") who access or interact with the Platform.

ZD77 is an English-language information and education service designed for users across Pakistan, including those in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We provide editorial content on sports betting, live casino gaming and responsible gambling. We do not operate a casino, sportsbook or real-money gaming service, and we do not process financial transactions on behalf of users.

By accessing the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of it, please discontinue use of the Platform. This Policy should be read alongside our Terms & Conditions, which govern your overall use of ZD77.

02 Definitions

In this Privacy Policy the following terms have the meanings set out below:

• "Personal Data" — any information that identifies or can be used to identify a natural person, directly or indirectly, including but not limited to names, email addresses, IP addresses and device identifiers.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. ZD77 is the Data Controller in respect of Personal Data collected via this Platform.
• "Data Processor" — a third party that Processes Personal Data on behalf of ZD77, subject to a binding data-processing agreement.
• "Cookies" — small text files placed on a User's device by a website to store session or preference information.
• "Consent" — a freely given, specific, informed and unambiguous indication of agreement to the Processing of Personal Data for a stated purpose.
• "Applicable Law" — all laws and regulations governing privacy and data protection applicable to ZD77 and its users, including the Pakistan Electronic Crimes Act 2016 where relevant.

03 Data Controller

ZD77, operating the Platform at https://zd77.cam, is the Data Controller responsible for Personal Data collected through this website. ZD77 does not hold a physical office in Pakistan and does not claim endorsement, affiliation or regulatory approval from the Government of Pakistan, the Pakistan Telecommunication Authority, the State Bank of Pakistan or any Pakistani provincial authority.

For all data-related enquiries, requests and complaints, please contact us using the details set out in Section 15 of this Policy.

04 Personal Data We Collect

4.1 Data You Provide Directly

ZD77 is primarily an informational platform and does not require account registration to access most content. Where the Platform includes optional contact or feedback mechanisms, the data you voluntarily provide may include:

• Email address (for support enquiries or correspondence);
• Name or display name (if provided in communications);
• The content of messages, queries or feedback you submit.

4.2 Data Collected Automatically

When you visit ZD77, our servers and analytics tools automatically collect certain technical data, including:

4.3 Data We Do Not Collect

ZD77 does not collect payment card numbers, bank account details, national identity card numbers or biometric data. We do not collect or store passwords — the Platform does not operate a user-account registration system that requires password authentication.

05 Legal Basis for Processing

ZD77 processes Personal Data on one or more of the following lawful bases:

• Legitimate Interests: Processing of technical log data and analytics for the purpose of maintaining platform security, preventing fraud and improving user experience — where such processing does not override Users' fundamental privacy interests.
• Consent: Where you voluntarily submit personal data via a contact form or enquiry, your act of submission constitutes consent for us to process that data solely in order to respond to your request.
• Legal Obligation: Where processing is required to comply with applicable laws, regulations or lawful requests from competent authorities.
• Contractual Necessity: Where processing is necessary to provide access to the Platform in accordance with our Terms & Conditions.

06 How We Use Your Personal Data

ZD77 uses Personal Data collected via the Platform exclusively for the following purposes:

• To deliver, maintain and improve the Platform and its content;
• To respond to support, privacy or responsible-gambling enquiries submitted by Users;
• To monitor and enforce compliance with our Terms & Conditions;
• To detect, investigate and prevent fraudulent, abusive or unlawful activity on the Platform;
• To generate aggregated, anonymised analytics that inform editorial and technical decisions;
• To comply with applicable legal obligations and to respond to lawful requests from competent authorities.

ZD77 does not use Personal Data for automated decision-making that produces legal or similarly significant effects on Users. We do not build individual behavioural profiles for targeted advertising purposes.

07 Cookies & Similar Tracking Technologies

7.1 Types of Cookies Used

ZD77 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for basic platform functionality — session management, security tokens and load-balancing. These cannot be disabled without impairing site operation.
• Analytics Cookies: Collect anonymised data on how Users interact with the Platform — pages visited, time on site, navigation paths. This data is aggregated and does not identify individual Users.
• Preference Cookies: Store User interface preferences (such as font-size or theme settings) to improve subsequent visits.

7.2 Managing Your Cookie Preferences

You can control and manage cookies through your browser settings at any time. Most modern browsers allow you to block or delete cookies, or to receive a notification before a cookie is stored. Please note that disabling strictly necessary cookies may prevent certain features of the Platform from functioning correctly.

ZD77 does not use third-party advertising cookies or cross-site tracking pixels. Analytics data collected via cookies is processed in aggregate form only.

08 Data Sharing & Third-Party Disclosure

ZD77 does not sell, rent, lease or trade Personal Data with any third party for commercial or marketing purposes. Personal Data may be disclosed in the following limited circumstances only:

• Service Providers (Data Processors): ZD77 engages carefully vetted third-party service providers — such as hosting infrastructure, content delivery networks and analytics platforms — that process Personal Data on our behalf and under binding data-processing agreements that restrict use to the purposes we specify.
• Legal Requirements: We may disclose Personal Data where required by applicable law, court order or lawful request from a competent governmental or regulatory authority — and only to the extent strictly necessary.
• Protection of Rights: We may disclose Personal Data where necessary to investigate, prevent or respond to suspected fraud, security incidents or violations of our Terms & Conditions.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of ZD77's business assets, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

Payment-method names referenced on ZD77 — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are editorial contextual references only. ZD77 does not share user data with these entities, and no data-sharing relationship with these providers exists or is implied.

09 Data Retention

ZD77 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention guidelines apply:

• Support & Correspondence Data: Retained for up to 12 months from the date of last communication, unless a longer period is required to resolve an ongoing dispute or legal matter.
• Server Log Data: Retained for up to 90 days for security and fraud-monitoring purposes, then deleted or anonymised.
• Analytics Data: Stored in aggregated, anonymised form with no defined maximum retention period, as it no longer constitutes Personal Data once anonymised.
• Cookie Data: Session cookies are deleted when the browser session ends. Persistent cookies expire as defined at the point of placement — typically within 12 months.

When Personal Data is no longer required, ZD77 deletes it securely or anonymises it such that it can no longer be attributed to an identifiable individual.

10 Your Data Rights

Subject to applicable law, you have the following rights in relation to your Personal Data held by ZD77. To exercise any of these rights, contact us using the details in Section 15. We will respond within a reasonable timeframe — typically within 30 days of receipt.

11 Security Measures

ZD77 implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• 256-bit TLS (HTTPS) encryption for all data in transit between your browser and our servers;
• Encryption of Personal Data stored at rest using industry-standard algorithms;
• Access controls limiting Personal Data access to authorised personnel on a strict need-to-know basis;
• Regular security reviews and vulnerability assessments of Platform infrastructure;
• Incident response procedures for detecting, reporting and addressing Personal Data breaches.

While ZD77 takes data security seriously, no system is entirely immune to risk. In the unlikely event of a data breach that poses a risk to your rights and freedoms, ZD77 will notify affected Users in accordance with applicable legal obligations.

12 Minors

ZD77 is strictly intended for users aged 18 years and above — or the higher minimum age required by the operator or license jurisdiction. We do not knowingly collect Personal Data from individuals under the age of 18. If you are a parent or guardian and believe that a minor has provided Personal Data to ZD77, please contact us immediately using the details in Section 15 and we will take steps to delete such data promptly.

13 International Data Transfers

As an online platform, ZD77 may use hosting, content delivery or analytics infrastructure located in jurisdictions outside Pakistan. Where Personal Data is transferred internationally, ZD77 ensures that appropriate safeguards are in place — such as standard contractual clauses, data-processing agreements or equivalent mechanisms — to protect your data to a standard consistent with this Privacy Policy.

ZD77 does not transfer Personal Data to jurisdictions without adequate data protection frameworks unless appropriate safeguards are contractually established.

14 Changes to This Privacy Policy

ZD77 reserves the right to update this Privacy Policy at any time to reflect changes in our data-processing practices, legal obligations or platform functionality. The most current version will always be published at https://zd77.cam/privacy-policy and identified by the "Last updated" date at the top of this document.

We recommend that Users review this Policy periodically. Where changes are material, ZD77 will take reasonable steps to notify Users — for example, by posting a prominent notice on the Platform homepage. Continued use of the Platform after a revised Policy is published constitutes acceptance of the updated terms.

15 Contact Us & Complaints

For any questions, requests or complaints relating to this Privacy Policy or the processing of your Personal Data, please contact the ZD77 Data Privacy team. We aim to respond to all data-related requests within 30 days of receipt and to resolve complaints promptly and fairly.

If you are not satisfied with our response, you may have the right to lodge a complaint with a relevant supervisory authority. ZD77 will cooperate in good faith with any such process.