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1. Who We Are
This Privacy Policy is issued by zb22, the operator of the online casino and sports betting platform accessible at https://zb22.pro and any associated mobile applications or sub-domains operating under the zb22 brand (collectively referred to as "the Platform", "we", "us", or "our").
zb22 operates under an international gaming license and serves users across Pakistan, providing cricket betting, live casino games, slots, Teen Patti 20-20, fishing games, and a range of other online gaming products. zb22 acts as the data controller in respect of all personal data collected through the Platform.
If you have any questions about this Privacy Policy or about how your personal data is handled, please contact our Data Protection team at [email protected] before creating an account or submitting any personal information.
Scope: This Privacy Policy applies to all registered users, prospective users who browse the Platform without registering, and any individual who contacts zb22 through our customer support channels. It covers all personal data collected online — through the website, mobile platform, live chat, and email correspondence.
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2. Data We Collect
zb22 collects personal data through several channels: directly from you when you register or interact with the Platform, automatically through technical systems as you use the Platform, and from third-party verification and payment service providers. The categories of data we collect are as follows:
2.1 Registration & Identity Data
- Full legal name as it appears on your government-issued identification;
- Date of birth (required for mandatory age verification — you must be 21 or older);
- Residential address, including city (Karachi, Lahore, Islamabad, Faisalabad, or any other Pakistani city);
- Pakistani mobile phone number (used for account security and two-factor authentication);
- Email address;
- Username and encrypted password.
2.2 Identity Verification Documents
- Copy of CNIC (Computerised National Identity Card) or passport;
- Proof of residential address (utility bill, bank statement);
- Source-of-funds documentation where required by AML compliance procedures;
- Selfie or live photograph for biometric identity matching (where applicable).
2.3 Financial & Transaction Data
- JazzCash and EasyPaisa mobile wallet identifiers (phone numbers associated with your wallet);
- Bank account details for HBL, UBL, Meezan Bank, or other supported institutions used for Raast or 1LINK transfers;
- Full transaction history including deposits, withdrawals, bets placed, game results, and bonus activity;
- PKR amounts involved in all financial transactions on the Platform.
2.4 Technical & Usage Data
- IP address and approximate geolocation derived from IP;
- Device type, operating system, and browser type;
- Session duration, pages visited, games played, and betting patterns;
- Login timestamps and access logs.
2.5 Communications Data
- Content of live chat conversations with our support team;
- Email correspondence;
- Complaint records and dispute documentation.
Sensitive Data: zb22 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data. If any such information is inadvertently disclosed in a support communication, it will not be recorded or processed for any purpose.
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3. How We Use Your Data
zb22 uses your personal data only for legitimate, specified purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes for which your data is used are:
| Purpose |
Data Used |
| Account Registration & Management |
Name, email, phone number, username, password |
| Age & Identity Verification (KYC) |
Date of birth, CNIC/passport, selfie, address documents |
| Payment Processing |
JazzCash/EasyPaisa details, bank account info, transaction history |
| AML & Fraud Prevention |
Transaction data, IP address, device info, source-of-funds docs |
| Responsible Gaming Monitoring |
Betting patterns, session duration, deposit frequency |
| Customer Support |
Communications data, account history, transaction records |
| Platform Improvement & Analytics |
Usage data, device/browser info, session data (anonymised where possible) |
| Marketing Communications |
Email address, phone number (only with your explicit consent) |
| Legal & Regulatory Compliance |
All categories as required by applicable laws and our gaming license |
You may opt out of marketing communications at any time by contacting us at [email protected] or using the unsubscribe link in any promotional email. Opting out of marketing will not affect the processing of your data for operational or compliance purposes.
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4. Legal Basis for Processing
zb22 processes your personal data on the following legal grounds, depending on the nature of the processing activity:
- Contractual Necessity: Processing your registration data, identity verification documents, and payment information is necessary to enter into and perform the contract between you and zb22 (i.e., to provide you with access to the Platform and to process your bets and financial transactions);
- Legal Obligation: Certain processing activities — particularly KYC identity verification, AML transaction monitoring, and the retention of records — are required by the laws and regulations applicable to zb22's international gaming license;
- Legitimate Interests: zb22 processes technical and usage data on the basis of its legitimate interest in maintaining platform security, preventing fraud, improving its services, and protecting other users;
- Consent: Where zb22 sends you promotional communications or uses non-essential cookies, this is done only on the basis of your freely given, informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.
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5. Sharing Your Data
zb22 does not sell, rent, or otherwise commercially exploit your personal data. We share your personal information only in the following limited circumstances and only with parties who are contractually bound to protect it:
- Payment Processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and 1LINK — solely for the purpose of processing your deposits and withdrawals in PKR;
- KYC & Identity Verification Providers: Third-party services used to verify your CNIC, passport, or address documents as required by our gaming license;
- Game Software Providers: Our casino game technology partners receive session identifiers and game interaction data to deliver game functionality and resolve technical disputes;
- Regulatory Authorities: zb22 may be required to disclose your data to licensing authorities, financial intelligence units, or law enforcement agencies where required by law or in connection with an investigation into suspected fraud, money laundering, or match-fixing;
- IT & Security Service Providers: Hosting infrastructure, cybersecurity, and platform monitoring vendors who process data strictly as data processors under our instructions.
No Third-Party Advertising: zb22 does not share your personal data with advertising networks, social media platforms, or data analytics companies for targeted advertising purposes. Your gaming activity and personal profile will never be sold to external marketers.
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6. Cookies & Tracking Technologies
The zb22 Platform uses cookies and similar tracking technologies to ensure the website functions correctly, to keep you securely logged in, and to understand how the Platform is being used so we can improve it over time.
We use the following categories of cookies:
- Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core site functionality;
- Functional Cookies: Remember your preferences such as language settings, preferred payment method display, and responsible gaming limit notifications;
- Analytics Cookies: Used to understand aggregate traffic patterns and user behaviour on the Platform. Data collected through analytics cookies is anonymised or pseudonymised before analysis. We use this data only to improve the Platform's performance and user experience;
- Security Cookies: Assist in detecting and preventing fraudulent login attempts, account takeovers, and bot activity.
zb22 does not use third-party advertising or retargeting cookies. You can manage your cookie preferences through your browser settings at any time. Please be aware that disabling certain cookies may impair the functionality of some features of the Platform.
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7. Data Retention
zb22 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming license obligations. Our standard retention periods are as follows:
- Account & Identity Data: Retained for a minimum of 5 years from the date of account closure, as required by AML and gaming regulatory obligations;
- Transaction & Betting Records: Retained for a minimum of 5 years from the date of each transaction;
- KYC Documents (CNIC/Passport copies): Retained for a minimum of 5 years from the date of verification;
- Customer Support Communications: Retained for 3 years from the date of the last interaction;
- Technical & Usage Logs: Retained for 12 months on a rolling basis, after which they are anonymised or deleted;
- Marketing Consent Records: Retained for the duration of your account and for 3 years after account closure as proof of consent.
When retention periods expire, personal data is securely deleted or anonymised in accordance with industry-standard data destruction procedures. Where data is subject to an ongoing legal dispute or regulatory investigation, retention may be extended until the matter is resolved.
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8. Security Measures
zb22 takes the security of your personal data extremely seriously. We implement a comprehensive, layered approach to data security that includes both technical and organisational measures:
- 256-bit SSL/TLS Encryption: All data in transit between your device and zb22 servers is encrypted using industry-standard SSL/TLS protocols;
- Encryption at Rest: Sensitive personal data including identity documents and financial information is encrypted at rest using AES-256 encryption;
- Access Controls: Personal data is accessible only to authorised zb22 staff on a strict need-to-know basis. All staff access to personal data is logged and subject to regular audit;
- Two-Factor Authentication: All zb22 internal systems that process personal data require multi-factor authentication for staff access;
- Regular Security Audits: zb22 conducts regular penetration testing and vulnerability assessments on its platform infrastructure;
- Incident Response: In the event of a personal data breach, zb22 will notify affected users and the relevant regulatory authority within the timeframes required by applicable law.
Your Responsibility: While zb22 takes all reasonable technical precautions, you are responsible for maintaining the security of your own account credentials. Never share your password or OTP codes with anyone — including anyone claiming to be a zb22 staff member. zb22 will never ask for your password via email, live chat, or phone call.
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9. Your Rights
As a user of the zb22 Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with your registered username or phone number so we can locate your account:
1
Right of Access
You have the right to request a copy of all personal data that zb22 holds about you. We will provide this in a structured, commonly used format within 30 days of your verified request.
2
Right to Rectification
If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Please note that changes to identity or KYC data may require re-verification.
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Right to Erasure
You may request deletion of your personal data. However, zb22 is required to retain certain data for regulatory compliance purposes. We will inform you of any data that cannot be deleted and the reason why.
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Right to Restrict Processing
You may request that we limit how we use your personal data in certain circumstances — for example, while a dispute about the accuracy of the data is being resolved.
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Right to Data Portability
Where processing is based on your consent or a contract, you have the right to receive your personal data in a machine-readable format so that you can transfer it to another service provider.
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Right to Object
You may object to processing based on legitimate interests, including profiling for marketing purposes. Where you object to marketing communications, we will stop processing your data for that purpose immediately.
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Right to Withdraw Consent
Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before the withdrawal.
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10. Children & Minors
The zb22 Platform is strictly intended for individuals who are 21 years of age or older. zb22 does not knowingly collect, store, or process personal data relating to any individual under the age of 21.
As part of our mandatory age verification process, all users are required to provide proof of age before their account is fully activated and before any deposits or bets can be placed. Where there is any doubt about a user's age, zb22 will suspend the account and request documentary proof of age (CNIC or passport) before reinstating access.
If you believe a minor has registered on zb22: Please contact us immediately at
[email protected]. We will investigate and take immediate action, including account suspension and deletion of any personal data collected, without delay. Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms.
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11. International Data Transfers
zb22 operates under an international gaming license, and as such, some of your personal data may be processed by servers or service providers located outside Pakistan. Where personal data is transferred internationally, zb22 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required within Pakistan.
These safeguards include:
- Contractual data processing agreements with all third-party processors that include binding data protection obligations;
- Transfer only to jurisdictions that maintain adequate data protection standards;
- Encryption of all data in transit across international networks.
For full details of where your data is processed and the specific safeguards applicable to international transfers, please contact us at [email protected].
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12. Third-Party Services
The zb22 Platform integrates with third-party service providers to deliver its gaming products and payment infrastructure. Each of these providers operates under their own privacy policies and data processing terms, which zb22 has reviewed and approved as part of its vendor due diligence process.
zb22 is not responsible for the privacy practices of third-party payment platforms (such as JazzCash and EasyPaisa) or game software providers once your interaction moves directly to their interfaces. We recommend reviewing the privacy policies of any third-party service you use in connection with your zb22 account.
No External Links: The zb22 Privacy Policy covers only the data processed directly by zb22. Any data entered into third-party payment apps (e.g., the JazzCash or EasyPaisa mobile apps on your phone) is governed by those providers' own privacy policies and is outside the scope of this document.
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13. Changes to This Privacy Policy
zb22 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our gaming license requirements. When we make material changes to this Policy, we will notify registered users via the email address or mobile number associated with their account, with a minimum of seven (7) days' notice prior to the changes taking effect.
Non-material changes — such as typographical corrections or clarifications that do not affect how your data is used — may be made without prior notice. The "Last Updated" date at the top of this document will always indicate the date of the most recent revision.
Continued use of the zb22 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes, you must stop using the Platform and request account closure before the revised Policy takes effect.
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14. Contact & Complaints
If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data zb22 holds about you, please contact our Data Protection team through the following channel:
- Email: [email protected]
- Subject Line: Please use "Privacy Request — [Your Username]" so your query is routed to the correct team promptly
- Response Time: We aim to acknowledge all privacy-related queries within 48 hours and provide a full response within 30 days
If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the data protection supervisory authority applicable under zb22's international gaming license. Details of the relevant authority are available from our customer support team upon request.