Privacy Policy — CZ111 Platform

This Privacy Policy ("Policy") sets out the data practices of CZ111, the online casino and sports betting information platform operated at cz111.cam ("CZ111", "Platform", "we", "us", "our"). This Policy applies to all users ("User", "you", "your") who access the Platform, whether as a registered account holder or a visitor browsing publicly available content.

CZ111 is committed to protecting the privacy of its users and to processing personal data in a manner that is transparent, proportionate and consistent with applicable data protection principles. We recognise that users based in Pakistan entrust us with their personal information and we take that responsibility seriously.

By accessing or using the CZ111 Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein, to the extent that such consent is required by applicable law. This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform more broadly.

The following defined terms are used throughout this Policy:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, either alone or in combination with other data.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, CZ111.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller under contractual arrangements.
• "Consent" means a freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• "Cookie" means a small text file placed on a user's device by a website to store session or preference information.
• "KYC" means Know Your Customer — identity verification procedures applied to registered account holders.
• "AML" means Anti-Money Laundering — compliance obligations requiring financial service providers to detect and prevent money laundering activity.
• "Third Party" means any natural or legal person other than the User and CZ111.

CZ111 collects personal data in several categories depending on how you interact with the Platform. The following table summarises the principal data types collected:

CZ111 does not intentionally collect sensitive personal data — such as data concerning racial or ethnic origin, political opinions, religious beliefs, health status or biometric identifiers — unless specifically required for regulatory compliance and with your explicit consent or a lawful basis.

The majority of the personal data we hold is provided directly by you during the registration process, account management, KYC verification, deposit or withdrawal transactions, or when you contact our support team. This includes information entered into forms, uploaded as documents or communicated via chat or email.

When you access cz111.cam, certain technical data is collected automatically through standard web technologies including cookies, server logs and similar mechanisms. This includes your IP address, browser type, device identifiers and session activity. This data is collected to maintain Platform security, detect fraud and improve the user experience.

In certain circumstances CZ111 may receive personal data from third-party sources, including:

• Identity verification service providers engaged to support KYC processes.
• Payment processors or financial intermediaries in the course of transaction processing. References to payment infrastructure such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are for contextual illustration only — data sharing with any specific provider is governed by the applicable transaction flow and that provider's own terms.
• Fraud prevention and AML screening providers.
• Analytics providers who supply aggregated or pseudonymised insight data.

CZ111 relies on one or more of the following lawful bases when processing your personal data:

• Contractual Necessity: Processing necessary to perform the contract with you — including operating your account, processing transactions and providing Platform services.
• Legal Obligation: Processing required to comply with applicable legal obligations, including KYC, AML and record-keeping requirements imposed on licensed operators.
• Legitimate Interests: Processing necessary for CZ111's legitimate business interests — including fraud prevention, Platform security, service improvement and responsible gambling monitoring — provided those interests are not overridden by your rights and interests.
• Consent: Where no other lawful basis applies and where required by applicable law, we will seek your explicit consent before processing. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

CZ111 uses the personal data we collect for the following purposes:

To create and maintain your account, verify your identity, process deposits and withdrawals, manage bonuses, apply responsible gambling controls and provide customer support. This processing is necessary for the performance of our contract with you.

To comply with KYC and AML obligations, detect and prevent fraud, money laundering, underage gambling and other prohibited activities. This processing is required by legal obligation and legitimate interest.

To monitor usage patterns for indicators of problem gambling behaviour, apply account limits and restrictions where appropriate, and facilitate self-exclusion requests. This processing serves both our legitimate interests and your welfare.

To send you transactional communications including account activity notifications, deposit and withdrawal confirmations, KYC status updates and security alerts. These communications are necessary for the performance of the contract and are not subject to marketing opt-out.

With your consent, or where permitted under applicable law, we may send promotional communications about bonuses, new games, sporting events and Platform features. You may opt out of marketing communications at any time by updating your account preferences or contacting support.

To analyse usage patterns, identify technical issues, test new features and improve the overall platform experience. Where possible, this analysis uses aggregated or pseudonymised data.

CZ111 does not sell, rent or trade personal data. We may share your personal data with third parties only in the following circumstances:

We engage third-party Data Processors to assist in operating the Platform. These include payment processing intermediaries, identity verification providers, fraud detection services, IT hosting and infrastructure providers, and customer support tools. All Data Processors are engaged under contractual terms that restrict their use of personal data to the stated purpose and require appropriate security measures.

We may disclose personal data to law enforcement authorities, regulatory bodies, courts or other government agencies where required to do so by applicable law, legal process or in response to a valid legal request. We will notify you of such disclosure where permitted by law.

In the event of a merger, acquisition, asset sale or restructuring involving CZ111, personal data may be transferred to the acquiring or succeeding entity as part of that transaction. You will be notified of any such transfer and the Privacy Policy applicable to your data following the transaction.

We may disclose personal data where necessary to protect the rights, property or safety of CZ111, its users or third parties — including in the context of fraud investigation, Terms & Conditions enforcement or security incident response.

CZ111 uses cookies and similar technologies (including local storage and session identifiers) to operate the Platform effectively. Below is a summary of the principal cookie categories in use:

You may manage non-essential cookies through your browser settings. Please note that disabling cookies may affect Platform functionality — in particular, session management and login functions may be impaired if strictly necessary cookies are blocked by browser configuration.

CZ111 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any legal obligations that require longer retention periods. The principal retention considerations are as follows:

• Active Account Data: Retained for the duration of your account registration and for a defined period following account closure, to support dispute resolution and audit requirements.
• KYC and AML Records: Retained for the period required by the applicable licensing jurisdiction's AML regulations — commonly a minimum of five years from the date of the relevant transaction or account closure, whichever is later.
• Transaction Records: Financial transaction records are retained for a period consistent with applicable accounting, tax and regulatory record-keeping obligations.
• Support Communications: Correspondence and support transcripts are retained for a period sufficient to resolve disputes and for quality assurance, typically not exceeding three years from the date of the communication.
• Analytics Data: Aggregated or pseudonymised analytics data may be retained indefinitely as it does not constitute personal data once it can no longer be attributed to an individual.

When personal data is no longer required, it is securely deleted or anonymised in accordance with our data lifecycle management procedures.

Subject to applicable law and the lawful basis on which your data is processed, you have the following rights with respect to personal data held by CZ111:

You may request confirmation of whether CZ111 holds personal data about you and, if so, a copy of that data together with information about how it is used. We will respond to verified access requests within a reasonable timeframe.

If personal data held about you is inaccurate or incomplete, you have the right to request its correction. You may update many account details directly within your account settings without contacting support.

You may request deletion of your personal data where: it is no longer necessary for the purpose for which it was collected; you withdraw consent and no other lawful basis applies; or processing was unlawful. This right is subject to overriding legal obligations — for example, KYC and AML records that must be retained under applicable regulatory requirements cannot be deleted on request before the mandated retention period expires.

You may request that CZ111 restrict processing of your personal data in certain circumstances — for example, where accuracy is contested, where processing is unlawful but you prefer restriction to deletion, or where you have objected to processing pending resolution of that objection.

Where processing is based on consent or contractual necessity and is carried out by automated means, you may request a structured, commonly used, machine-readable copy of personal data you have provided to CZ111.

You may object to processing based on legitimate interests, including direct marketing. Where you object to marketing communications, CZ111 will cease that processing immediately. Where you object to other legitimate-interest processing, we will assess whether our interests override your rights.

CZ111 may use automated systems to support fraud detection and responsible gambling monitoring. Where automated processing produces decisions that significantly affect you, you have the right to request human review of that decision.

CZ111 implements and maintains technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• HTTPS/TLS encryption for all data in transit between your device and the Platform.
• Encrypted storage of sensitive data fields, including identity and payment reference data.
• Role-based access controls limiting personal data access to authorised personnel with a documented need.
• Regular security review procedures, including vulnerability assessments.
• Two-factor authentication available to users for account-level protection.
• Incident response procedures for detecting, reporting and responding to personal data breaches.

Notwithstanding the above, no data transmission over the internet or electronic storage system is guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your own account credentials. If you suspect your account has been compromised, contact us at [email protected] immediately.

CZ111's Platform and infrastructure may involve the transfer and processing of personal data in countries outside Pakistan. Where personal data is transferred internationally — for example, to cloud hosting providers or identity verification services — CZ111 takes steps to ensure that appropriate safeguards are in place, including contractual protections with Data Processors that require them to apply standards consistent with those described in this Policy.

By using the Platform, you acknowledge that your personal data may be processed in jurisdictions other than Pakistan. CZ111 does not make any representation that processing in a specific jurisdiction is consistent with Pakistani law, as no comprehensive domestic data protection law is currently in force in Pakistan.

The CZ111 Platform is strictly intended for adults aged 18 years or over — or the higher minimum age required by the operator or license jurisdiction. CZ111 does not knowingly collect personal data from individuals under the applicable minimum age.

If we become aware that personal data has been submitted by or on behalf of a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please notify us at [email protected] as a matter of urgency.

Parents and guardians are encouraged to monitor internet access and apply parental control tools to prevent minors from accessing online gambling platforms. Age verification being 18+ does not imply that gambling is lawful for that individual in Pakistan or any other jurisdiction.

The CZ111 Platform may incorporate content or services provided by third-party technology partners — including game studios, sports data providers, live streaming services and payment infrastructure. These third parties operate under their own privacy policies and CZ111 is not responsible for the data practices of third-party services beyond the contractual obligations we impose on our Data Processors.

If you interact with third-party content embedded within the Platform — such as a live game streamed from a third-party studio — your interactions may be subject to that party's data practices in addition to those described in this Policy. We recommend reviewing the privacy notices of any third-party services you engage with.

CZ111 reserves the right to update or revise this Privacy Policy at any time. Material changes will be communicated to registered users via the email address on record and/or through a prominent notice on the Platform. The effective date at the top of this document will be updated to reflect the date of the most recent revision.

Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree with the revised Policy, you may request account closure by contacting our support team.

We encourage you to review this Policy periodically to remain informed of how CZ111 handles your personal data.

If you have any questions, concerns or requests relating to this Privacy Policy or the manner in which CZ111 handles your personal data, please contact us using the details below. We treat all privacy-related enquiries with priority and will respond within a reasonable timeframe.

Email: [email protected]

When contacting us regarding a data subject rights request, please include your registered account email address or account reference number to allow us to verify your identity and locate your data efficiently.

Support is available in English. Urdu-language assistance may be available during selected hours. All formal data subject requests should be submitted in writing to the email address above.