cz111 Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") describes how cz111 ("the Company," "we," "us," "our") collects, uses, stores, and protects the personal information of players and visitors who access the cz111 platform at cz111.org, including all associated subdomains, mobile-optimised pages, and any related services (collectively, "the Platform").

cz111 operates as Pakistan's premier online casino and sportsbook, serving players in Karachi, Lahore, Islamabad, Faisalabad, and across the country. We are committed to handling your personal data responsibly, transparently, and in accordance with applicable international data protection standards.

This Policy applies to all personal data provided to us by you directly — for example, during account registration or KYC verification — as well as data we collect automatically through your use of the Platform, such as device identifiers, IP addresses, and gameplay activity.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, both of which form part of your overall agreement with cz111.

2 Data We Collect

cz111 collects personal data in the following categories:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data except where strictly required by responsible gaming obligations (for example, self-exclusion records).

3 How We Use Your Data

cz111 uses the personal data we collect for the following purposes:

• Account creation and management: To register your cz111 account, verify your identity, and maintain your account in good standing throughout your time on the platform.
• Transaction processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and standard bank transfer, and to maintain accurate financial records of all account activity.
• KYC and regulatory compliance: To verify that you meet the minimum age requirement of 21 years, to comply with anti-money laundering (AML) obligations, and to satisfy any applicable international licensing requirements.
• Responsible gaming: To monitor for signs of problem gambling behaviour, to enforce self-exclusion requests, and to apply deposit or loss limits you have set on your account.
• Fraud prevention and security: To detect and investigate suspicious account activity, fraudulent transactions, multi-accounting, and any other conduct that violates the cz111 Terms and Conditions.
• Customer support: To respond to your queries, process complaints, and provide assistance through our 24/7 live chat service.
• Platform improvement: To analyse usage patterns and technical performance data to improve the reliability, speed, and quality of the cz111 platform for all players.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided explicit consent to receive such communications. You may withdraw consent at any time.

4 Legal Basis for Processing

cz111 processes your personal data on the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing required to perform our contract with you — including account management, transaction processing, and provision of games and sportsbook services.
• Legal obligation: Processing required to comply with applicable laws and regulatory requirements, including AML obligations and KYC verification mandates under our international licensing framework.
• Legitimate interests: Processing carried out for cz111's legitimate business interests, including fraud prevention, security monitoring, platform analytics, and responsible gaming programme management — provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for which you have provided freely given, specific, informed, and unambiguous consent — principally in relation to marketing communications and non-essential cookies. You may withdraw consent at any time without detriment to your account.

5 Data Sharing & Disclosure

cz111 does not sell, rent, or trade your personal data to any third party for commercial purposes. Your data may be shared only in the following strictly limited circumstances:

• Payment processors: Financial data is shared with licensed payment service providers — including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other banking partners — solely to facilitate deposit and withdrawal transactions.
• Game providers: Limited technical and account identifiers may be shared with licensed game studios and live casino providers (such as Ezugi) to facilitate game access and session management.
• KYC and identity verification services: Identity documents and personal details may be processed by third-party identity verification providers engaged by cz111 to conduct mandatory KYC checks.
• Regulatory and legal authorities: cz111 may disclose personal data to relevant licensing authorities, law enforcement agencies, or courts when required to do so by applicable law or a valid legal order.
• Group companies: Data may be shared within the cz111 corporate group where necessary for the operation of the platform and provision of services to you.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of the cz111 business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

6 Data Retention

cz111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including the satisfaction of any legal, regulatory, accounting, or reporting obligations. The following general retention periods apply:

• Account and identity data: Retained for the lifetime of your cz111 account and for a minimum of five (5) years following permanent account closure, in compliance with AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable financial regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the business relationship, whichever is later.
• Responsible gaming records: Self-exclusion records and related responsible gaming data are retained for the duration of the exclusion period and for a minimum of two (2) years thereafter.
• Marketing preference data: Retained until you withdraw consent or close your account, whichever is earlier.
• Technical and usage data: Typically retained for twelve (12) months from the date of collection, unless retained longer for security investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with you as an identifiable individual.

7 Cookies & Tracking Technologies

The cz111 platform uses cookies and similar tracking technologies to operate correctly, maintain your session security, and improve your experience. The cookies we use fall into the following categories:

• Strictly necessary cookies: These are essential for the Platform to function. They enable core features such as secure login sessions, account balance display, and navigation. These cookies cannot be disabled as they are required for the site to work.
• Performance and analytics cookies: These cookies collect anonymised information about how visitors use the Platform — such as which pages are visited most frequently and whether any error messages are received. This data helps us improve the cz111 experience.
• Functional cookies: These cookies enable enhanced functionality such as remembering your language preferences, display settings, and responsible gaming tool configurations.
• Targeting and marketing cookies: Where you have provided consent, these cookies may be used to display relevant promotional content based on your platform activity. Non-essential marketing cookies are only set with your explicit consent.

You can control and manage cookies through your browser settings. Please note that disabling strictly necessary cookies will affect the functionality of the cz111 Platform and may prevent you from accessing your account or completing transactions.

8 Data Security

cz111 takes the security of your personal data seriously and maintains a comprehensive set of technical and organisational measures designed to protect your information against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS (Transport Layer Security) encryption for all data in transit between your device and cz111 servers
• Encryption of sensitive stored data including financial information and identity documents
• Strict access controls ensuring that only authorised personnel can access personal data, on a need-to-know basis
• Regular security audits and penetration testing of the cz111 platform infrastructure
• Monitoring systems to detect and respond to suspicious activity or potential data breaches in real time
• Staff training on data protection obligations and secure data handling procedures

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, cz111 will notify affected players without undue delay in accordance with applicable data protection standards.

9 Your Data Rights

Subject to applicable law and certain regulatory limitations, you have the following rights in relation to your personal data held by cz111:

• Right of access: You have the right to request a copy of the personal data cz111 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: In certain circumstances, you may request deletion of your personal data. Note that this right is subject to our legal obligation to retain certain data for AML and regulatory compliance purposes, which may take precedence.
• Right to restrict processing: You may request that cz111 restricts the processing of your personal data in certain circumstances, for example while the accuracy of data is being contested.
• Right to data portability: Where processing is based on your consent or on a contract, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out prior to withdrawal.
• Right to object: You have the right to object to processing based on legitimate interests, and to object to direct marketing communications at any time.

To exercise any of these rights, please contact the cz111 support team via live chat or by email at [email protected]. We will respond to all verifiable data rights requests within thirty (30) days. We may require proof of identity before processing your request.

10 Children & Minors

The cz111 platform is strictly intended for adults aged 21 years and above. We do not knowingly collect or process personal data from individuals under the age of 21. Age verification is a mandatory component of our registration and KYC process.

If cz111 becomes aware that personal data has been collected from an individual under the age of 21, we will immediately close the relevant account and securely delete all associated data. If you believe that a minor has registered on the cz111 platform, please notify us immediately via live chat support.

11 International Data Transfers

As a platform operating under an international gaming licence, cz111 may transfer your personal data to servers or service providers located outside of Pakistan. Where such transfers occur, cz111 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy.

Transfers to third-party service providers outside Pakistan — including game studios, payment processors, and identity verification providers — are governed by contractual data protection obligations that require those parties to maintain appropriate security measures and to use your data only for the purposes specified by cz111.

By using the cz111 platform, you acknowledge and consent to the transfer of your personal data as described in this section.

12 Changes to This Policy

cz111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or the services we provide. Material changes to this Policy will be communicated to registered players via email notification and/or prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Policy periodically to remain informed of how cz111 is protecting your personal data.

Your continued use of the cz111 platform following the effective date of any amended Policy constitutes your acceptance of the updated terms.

13 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way cz111 handles your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 on the cz111 Platform. Our support team can assist with all data-related enquiries.
• Email: [email protected] — please include "Privacy Request" in the subject line for data rights enquiries.

Formal privacy complaints will be acknowledged within 48 hours and investigated within 30 calendar days. If you are not satisfied with our response, you may have the right to escalate your complaint to the relevant data protection authority or regulatory body applicable in your jurisdiction.