Privacy Policy — zd33

1. Introduction

This Privacy Policy ("Policy") is issued by zd33 ("we", "us", "our") and describes how we collect, use, store, share and protect personal data in connection with your use of the website at https://zd33.cam ("Platform") and all associated services.

zd33 is an English-language online betting and gaming information platform built for Pakistani users. We take data protection seriously. Our approach is straightforward: collect only what we need, use it only for stated purposes, protect it rigorously, and give you meaningful control over your own information.

By accessing or using the Platform, you acknowledge that you have read and understood this Policy. This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which form part of your agreement with us.

2. Definitions

For clarity throughout this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, email address, phone number, financial data and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For this Platform, that is zd33.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under documented instructions.
• "User" / "you" means any individual who accesses, registers on or otherwise interacts with the Platform.
• "KYC Data" means identity verification documents and related information submitted in connection with Know Your Customer requirements.
• "Cookie" means a small text file placed on your device by the Platform to support session management, security and analytics functions.
• "Third Party" means any entity that is not zd33 or the User.

3. Data We Collect

We collect Personal Data in the following categories and circumstances:

3.1 Account Registration Data

When you create an account, we collect the information you provide directly, which typically includes:

• Full name;
• Email address;
• Date of birth (for age verification purposes);
• Country of residence and, where relevant, city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar);
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with age verification and anti-money-laundering (AML) obligations, we may collect:

• Government-issued identity document (e.g., Pakistani CNIC or passport — document number, name, photograph, date of birth and expiry date);
• Proof of address documentation where required;
• Selfie or liveness verification image for facial matching purposes.

3.3 Financial Transaction Data

When you make deposits or request withdrawals, we process transaction-related data including payment method type, transaction amounts in PKR, transaction reference numbers and timestamps. We do not store complete payment card numbers. Where familiar local payment methods are referenced (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah), these references are for contextual identification only.

3.4 Usage and Technical Data

We automatically collect certain technical data when you interact with the Platform:

• IP address and approximate geolocation (country/city level);
• Device type, operating system and browser version;
• Pages visited, time spent and navigation patterns;
• Session identifiers and cookie data (see Section 9).

3.5 Communications Data

If you contact our support team, we retain records of that correspondence — including the content of messages and any attachments you provide — for quality assurance, dispute resolution and regulatory compliance purposes.

4. Legal Basis for Processing

We process your Personal Data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform our agreement with you — including account operation, payment processing and customer support.
• Legal obligation: Processing required to comply with applicable laws, including age verification, AML obligations and regulatory reporting requirements.
• Legitimate interests: Processing where our legitimate business interests (such as fraud prevention, platform security and service improvement) are not overridden by your interests or fundamental rights.
• Consent: Where we rely on your consent — for example, for non-essential cookies or optional marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

5. How We Use Your Data

We use the Personal Data we collect for the following purposes:

• Account management: Creating and maintaining your registered account, authenticating your identity and managing your account settings.
• Age and identity verification: Confirming that you meet the minimum age requirement (18+ or higher where the operator/license jurisdiction requires) and that your identity is genuine.
• Payment processing: Facilitating deposits in PKR and processing withdrawal requests in accordance with the Operator's current policies.
• Fraud prevention and AML compliance: Detecting, investigating and preventing fraudulent transactions, money laundering, account abuse and other prohibited activity.
• Platform security: Monitoring for unauthorised access, technical threats and suspicious usage patterns to protect all users.
• Service improvement: Analysing anonymised usage patterns to improve Platform performance, usability and content relevance for Pakistani users.
• Customer support: Responding to your enquiries, complaints and support requests efficiently.
• Responsible gambling: Operating and enforcing self-exclusion, deposit limits, cooling-off periods and other responsible gambling tools you activate.
• Legal and regulatory compliance: Meeting our obligations under applicable laws and responding to lawful requests from competent authorities.

6. Data Sharing & Disclosure

We do not sell, rent or trade your Personal Data to third parties for their own marketing or commercial purposes. We may share your data only in the following limited, controlled circumstances:

6.1 Service Providers (Data Processors)

We engage carefully selected third-party service providers who process data on our behalf under binding data processing agreements. These may include identity verification providers, payment technology providers, fraud detection services, cloud hosting providers and analytics tools. All processors are contractually required to handle your data only for specified purposes and in accordance with our instructions.

6.2 The Operator

Where betting or gaming services are provided through a separately licensed Operator, relevant account and transaction data may be shared with that Operator to the extent necessary for the provision of those services. The Operator is subject to its own data protection obligations under its applicable regulatory framework.

6.3 Legal and Regulatory Authorities

We may disclose Personal Data to law enforcement agencies, regulatory authorities, courts or other public bodies where required or permitted to do so by applicable law — for example, in response to a valid court order, AML reporting obligation or fraud investigation.

6.4 Business Transfers

In the event of a merger, acquisition, asset sale or corporate restructuring, Personal Data held by zd33 may be transferred to the acquiring or successor entity. We will notify affected users as required by applicable law in such circumstances.

7. International Data Transfers

The zd33 Platform and its associated infrastructure may involve the transfer of Personal Data to servers or service providers located outside Pakistan. Where such transfers occur, we take appropriate measures to ensure that your data receives an equivalent level of protection to that which it would receive in Pakistan, including through the use of contractual safeguards with data processors.

Pakistan's data protection framework is evolving. The Personal Data Protection Bill, where and to the extent enacted, may impose additional requirements on such transfers. We will update our practices accordingly as applicable legislation comes into force.

8. Data Retention

We retain Personal Data for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal, regulatory, accounting and reporting obligations. Retention periods vary by data category:

After the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

9. Cookies & Tracking Technologies

The Platform uses cookies and similar technologies to support its operation. We use three categories of cookies:

9.1 Strictly Necessary Cookies

These are essential to the Platform's operation and cannot be disabled. They include session cookies that keep you logged in during your visit, security tokens that protect against cross-site request forgery, and load balancing cookies that ensure stable performance.

9.2 Analytics Cookies

We use anonymised analytics tools to understand how users navigate the Platform — which pages are most visited, where users encounter difficulties, and how the Platform performs on different devices and networks. This data is aggregated and does not identify you personally.

9.3 Preference Cookies

These cookies remember your Platform preferences — such as language settings and display preferences — so that you do not need to reconfigure them on each visit.

10. Your Rights

Subject to applicable law, you hold the following rights with respect to your Personal Data. To exercise any of these rights, please contact us using the details in Section 15.

We will respond to valid data rights requests within a reasonable timeframe. We may ask you to verify your identity before processing your request. Some requests may be subject to limitations under applicable law — for example, where retention is required for AML compliance.

11. Security Measures

We implement robust technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• 256-bit TLS encryption for all data in transit between your device and Platform servers;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Strict access controls limiting Personal Data access to authorised personnel with a legitimate need;
• Regular security assessments and penetration testing;
• Multi-factor authentication options for account security;
• Continuous monitoring for suspicious access patterns and potential breaches;
• Data processor due diligence and contractual security requirements.

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and relevant authorities as required by applicable law.

12. Children's Privacy

The zd33 Platform is strictly for adults. We do not knowingly collect Personal Data from individuals under the age of 18 — or the higher minimum age required by the applicable operator/license jurisdiction. Age verification is a mandatory step of our registration process.

If we discover or receive credible information that a user is under the minimum age requirement, we will suspend and close that account immediately, delete any Personal Data associated with it (subject to any legal retention obligations), and withhold any associated balance pending investigation.

13. Third-Party References & Links

This Policy covers only the processing of Personal Data by zd33. The Platform may reference third-party payment service names — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — as familiar context references for Pakistani users. These references do not imply any commercial relationship, endorsement or data-sharing arrangement with those institutions unless separately disclosed.

The Platform does not include links to external third-party websites beyond the zd33 domain. If you navigate to any external site independently, please note that we have no control over and accept no responsibility for the privacy practices of those sites.

14. Policy Amendments

We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law or Platform functionality. The "Last Updated" date at the top of this page will reflect the most recent revision.

Where changes are material — meaning they significantly affect how we process your Personal Data or the rights available to you — we will endeavour to provide reasonable advance notice through the Platform. Your continued use of the Platform following any update to this Policy constitutes acceptance of the revised terms.

We encourage all users to review this page periodically. If you disagree with any amendment, please cease using the Platform and contact us to exercise your data rights as described in Section 10.

15. Contact Us

If you have questions, concerns or complaints regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of the data rights described in Section 10, please contact the zd33 data team. We will respond within a reasonable timeframe. Our support language is English; Urdu assistance is available on request.

For further information about your rights on the Platform, please also review our Terms & Conditions, our Responsible Gambling page and our FAQ.