zhgame Privacy Policy
— Your Data, Your Rights

1. Who We Are

zhgame ("we," "us," "the Company," or "zhgame") is the legal entity responsible for operating the online sports betting and casino platform accessible at zhgame.net. For the purposes of this Privacy Policy, zhgame is the data controller — meaning we determine the purposes and means by which your personal data is processed.

This Privacy Policy applies to all personal data processed in connection with your use of the zhgame Platform, including data collected during account registration, identity verification, deposits, withdrawals, betting activity, live casino sessions, customer support interactions, and promotional communications. It applies to all Members regardless of the device or method used to access the Platform.

2. Personal Data We Collect

zhgame collects personal data across several categories, each serving a specific and documented operational purpose. The categories of personal data we collect are set out in the table below:

3. How We Collect Your Data

zhgame collects personal data through the following channels:

3.1 Direct Collection

The majority of personal data we hold is provided directly by you during the account registration process, KYC document submission, payment transactions, form completions, and communications with our support team. You have visibility and control over what you provide at each stage.

3.2 Automated Collection

When you access the Platform, certain technical data is collected automatically by our systems — including your IP address, device identifiers, browser characteristics, access timestamps, and navigation data. This collection occurs via standard web server logging, session management technology, and the cookie mechanisms described in Section 7 of this policy.

3.3 Third-Party Sources

In limited circumstances, zhgame may receive personal data from third-party sources, including identity verification service providers engaged for KYC purposes, payment processors confirming transaction details, and fraud detection services flagging anomalous activity. Data received from third parties is processed in accordance with the purposes described in this policy.

4. Legal Basis for Processing

zhgame processes your personal data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contract Performance: Processing necessary to register your account, process your deposits and withdrawals, settle your bets, and provide the services you have requested.
• Legal Obligation: Processing required to comply with applicable gaming licence conditions, anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and any other legal or regulatory obligation binding on zhgame.
• Legitimate Interests: Processing necessary for zhgame's legitimate business interests, including fraud detection, platform security, responsible gaming monitoring, and service improvement — provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided clear, freely given, and informed consent. You may withdraw consent for these purposes at any time as described in Sections 7 and 13 of this policy.

5. How We Use Your Personal Data

The personal data we collect is used for the following specific purposes:

• To create, verify, and manage your zhgame account throughout its lifecycle.
• To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/Mastercard, and USDT cryptocurrency channels.
• To verify your identity and age in accordance with our KYC obligations and to comply with anti-money laundering regulatory requirements.
• To settle your sports bets and casino game rounds accurately and in accordance with the applicable rules.
• To monitor your gaming activity for responsible gaming purposes, including identifying patterns that may indicate problematic gambling behaviour and implementing protective measures where appropriate.
• To detect, investigate, and prevent fraudulent activity, including detection of duplicate accounts, automated betting tools, and payment fraud.
• To communicate with you regarding your account, including transaction confirmations, security alerts, and support responses.
• To send you marketing communications about zhgame promotions, bonuses, and new features — only where you have provided consent or where permitted under applicable rules.
• To comply with our obligations under our international gaming licence, including reporting obligations and audit requirements.
• To improve the Platform's performance, user experience, and technical reliability based on aggregated usage analytics.

6. Data Sharing and Disclosure

zhgame does not sell your personal data to third parties. We share personal data only in the limited circumstances described below, and only to the extent necessary for each specific purpose:

6.1 Service Providers

We engage carefully vetted third-party service providers to support platform operations, including payment processors (for JazzCash, EasyPaisa, banking transfers, and card payments), identity verification providers, cloud hosting and infrastructure providers, customer support platform operators, and fraud detection services. All service providers are bound by contractual data processing agreements that prohibit them from using your data for any purpose other than delivering the specific service for which they have been engaged.

6.2 Regulatory and Law Enforcement Disclosure

zhgame may be required to disclose personal data to regulatory bodies, gaming licence authorities, financial intelligence units, or law enforcement agencies where such disclosure is required by applicable law, regulatory instruction, court order, or is necessary to investigate suspected criminal activity including money laundering or fraud. Such disclosures are made strictly on a need-to-know basis and are logged internally.

6.3 Corporate Transactions

In the event of a merger, acquisition, or sale of all or substantially all of zhgame's assets, your personal data may be transferred to the acquiring entity as part of that transaction, subject to commitments to maintain equivalent data protection standards. You will be notified of any such transfer in advance.

6.4 Aggregated Analytics

zhgame may share aggregated, anonymised statistical data about Platform usage with business partners and analytics providers. This data does not identify any individual Member and cannot reasonably be used to re-identify any person.

7. Cookies and Tracking Technologies

zhgame uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that enable the Platform to recognise your browser, maintain your session, and store certain preferences. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the Platform to function. These enable session management, secure login, and core functionality. They cannot be disabled without breaking the service.
• Functional Cookies: Remember your preferences such as language settings, currency display, and responsible gaming limits you have configured. These improve your experience but are not essential to the core service.
• Analytics Cookies: Collect anonymised data about how Members navigate the Platform — which pages are visited most, how long sessions last, and where technical errors occur. This data helps us improve the Platform.
• Marketing Cookies: Used to deliver relevant promotional content and to measure the effectiveness of marketing campaigns. These are only placed with your consent.

You can manage your cookie preferences through your browser settings at any time. Note that disabling strictly necessary cookies will impair your ability to use the Platform. Consent-based cookies may also be managed through the cookie preference centre accessible from the footer of the Platform.

8. Data Retention

zhgame retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods driven by regulatory obligations:

• Account and Identity Data: Retained for a minimum of five (5) years from the date of account closure, in compliance with AML record-keeping obligations applicable under our gaming licence.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with applicable financial record-keeping requirements.
• Gaming Activity Logs: Retained for a minimum of three (3) years from the date of each session, to support dispute resolution and responsible gaming review.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or from account closure, whichever is later.
• Support Communications: Retained for two (2) years from the date of each interaction, to support quality assurance and dispute resolution.
• Marketing Consent Records: Retained for the duration of your account relationship and for one (1) year following account closure or withdrawal of consent.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with zhgame's data destruction procedures.

9. Data Security

zhgame implements a layered approach to data security designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our security measures include:

• TLS encryption for all data in transit between your device and zhgame servers.
• Encryption at rest for all sensitive personal data stored in zhgame databases, including identity documents and financial data.
• Role-based access controls limiting staff access to personal data strictly to those with a documented operational need.
• Multi-factor authentication required for all administrative access to systems holding personal data.
• Regular penetration testing and vulnerability assessments conducted by independent security professionals.
• Automated intrusion detection and anomaly monitoring systems operating on a 24/7 basis.
• Incident response procedures enabling rapid containment and notification in the event of a data security incident.

Notwithstanding these measures, no internet-based system is entirely immune to security risks. We encourage you to use a strong, unique password for your zhgame account, enable two-factor authentication where available, and notify us immediately if you suspect any unauthorised access to your account.

10. International Data Transfers

As an internationally licensed platform, zhgame may process or store personal data on servers located outside Pakistan. Where personal data is transferred internationally, zhgame ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that which applies within the jurisdiction of our gaming licence.

Safeguards employed for international transfers include standard contractual clauses incorporated into agreements with service providers, data processing agreements containing binding obligations on recipient entities, and transfer only to jurisdictions or entities that provide an adequate level of data protection as recognised under applicable standards.

11. Your Data Protection Rights

Subject to applicable law and regulatory obligations, you have the following rights in relation to your personal data held by zhgame:

• Right of Access: You may request a copy of the personal data we hold about you. We will respond to verified access requests within 30 days.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you. Minor corrections (such as contact details) can often be made directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal or regulatory retention obligations (such as AML record-keeping requirements described in Section 8).
• Right to Restriction of Processing: You may request that we restrict processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to our processing.
• Right to Data Portability: You may request a structured, commonly used, machine-readable copy of personal data you have provided to us, where technically feasible.
• Right to Object: You may object to processing of your personal data based on legitimate interests, including profiling for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, contact zhgame's support team with your request. We may require identity verification before processing your request to protect against unauthorised access. We will not charge a fee for reasonable requests.

12. Children and Minors

The zhgame Platform is strictly for users aged 21 years and over. We do not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory component of the account registration and KYC process precisely to prevent minors from accessing the Platform.

If zhgame becomes aware that personal data has been collected from an individual under 21 years of age, the associated account will be permanently closed, all data will be deleted to the extent not required to be retained for regulatory purposes, and any funds deposited will be handled in accordance with our applicable regulatory obligations.

If you are a parent or guardian and believe that a minor under your care has registered on zhgame, please contact our support team immediately providing details of the account so we can take prompt action.

13. Marketing Communications and Preferences

zhgame may send you promotional communications about bonuses, new sports markets, PSL seasonal campaigns, live casino offers, and platform updates. The basis and method for these communications depends on your preferences and applicable rules:

• Email Marketing: Sent only where you have provided explicit consent during registration or via your account communications preferences. You may unsubscribe at any time using the unsubscribe link in any marketing email.
• SMS / Push Notifications: Sent only where you have opted in. You may withdraw consent by updating your notification preferences in your zhgame account settings.
• On-Platform Promotions: Displayed to all Members as part of the standard Platform interface. These are informational rather than individually targeted marketing communications.

Withdrawing consent for marketing communications will not affect your ability to use zhgame's core betting and gaming services. It will not affect processing carried out before your withdrawal of consent.

14. Changes to This Privacy Policy

zhgame reviews this Privacy Policy periodically and updates it when our data practices change or when required by applicable law or regulatory guidance. Material changes to the policy will be communicated to Members via email to the registered address and/or by a prominent notice on the Platform, at least seven (7) days before the change takes effect.

The date of the most recent update is displayed at the top of this policy. We encourage you to review this page periodically so that you remain informed about how we protect your personal data. Your continued use of the Platform following notification of a material change constitutes your acknowledgment of the updated policy.

15. Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a concern about how zhgame handles your personal data, please contact us through the following channels:

• Live Chat Support: Available 24/7 from your logged-in zhgame account dashboard — the fastest way to raise any account-related or data-related query.
• Email Contact (plain text — not a clickable link): [email protected] — please mark the subject line "DATA REQUEST" or "PRIVACY QUERY" for efficient routing.
• Data Deletion Requests: Submit via live chat or email with the subject "ERASURE REQUEST" along with your registered name and account email address.

zhgame will acknowledge privacy-related enquiries within 2 Business Days and aims to provide a substantive response within 30 days. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

If you are not satisfied with our response to a privacy complaint, you have the right to refer the matter to the relevant data protection supervisory authority applicable under our gaming licence jurisdiction.