01 Introduction
This Privacy Policy ("Policy") is issued by zk77 ("Platform", "we", "us", "our"), the operator of the online sports betting and gaming services accessible at zk77.cam. It describes how we collect, use, store, share and protect the personal data of individuals ("Users", "you", "your") who access or use the Platform.
zk77 is committed to handling personal data responsibly, transparently and in accordance with applicable data protection standards. This Policy is intended to give you a clear and honest account of our data practices so that you can make informed decisions about using the Platform.
By accessing the Platform, registering an Account or using any of our services, you acknowledge that you have read and understood this Policy. This Policy should be read alongside our Terms & Conditions, which govern the overall use of the Platform.
Pakistani Users — Local Legal Context: Pakistan's data protection landscape is evolving. zk77 does not claim that its data practices are certified or approved by the Government of Pakistan, the National Database & Registration Authority (NADRA), the Pakistan Telecommunication Authority (PTA), or any other Pakistani regulatory body. Users in Pakistan are responsible for understanding their own data rights under applicable local law. This Policy is informational and does not constitute legal advice.
02 Definitions
The following terms have the meanings set out below throughout this Policy:
03 Personal Data We Collect
zk77 collects only the Personal Data that is reasonably necessary for the purposes described in this Policy. The categories of data we may collect include:
3.1 Registration & Account Data
- Full legal name and date of birth;
- Email address and (where provided) phone number;
- Residential address, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) and country;
- Username and encrypted password;
- Account preferences and communication settings.
3.2 Identity Verification (KYC) Data
- Copies of government-issued identification documents (e.g., National Identity Card (CNIC), passport, driving licence);
- Proof of residential address documents (e.g., utility bills, bank statements);
- Source-of-funds documentation where required by applicable compliance obligations;
- Selfie or liveness verification data where applicable.
3.3 Financial & Transaction Data
- Deposit and withdrawal transaction records, including amounts in PKR, timestamps and payment method type;
- Payment instrument details to the extent necessary for processing and fraud prevention (we do not retain full card numbers in plain text);
- Account balance history and bonus utilisation records.
3.4 Betting & Gaming Activity Data
- Bet placement records, including market, stake, odds and settlement outcome;
- Casino game session logs, including game type, duration and RNG outcomes;
- Bonus and promotion participation history;
- Responsible gambling tool settings (e.g., deposit limits, self-exclusion status).
3.5 Technical & Device Data
- IP address and approximate geolocation derived therefrom;
- Browser type, version and language settings;
- Device type, operating system and screen resolution;
- Session duration, page visit logs and click-path data;
- Cookie identifiers and similar tracking technologies.
3.6 Communications Data
- Content of messages sent to our support team via Live Chat or email;
- Records of complaints and dispute submissions, including reference numbers and resolution notes;
- Email marketing interaction data where you have opted in to receive promotional communications.
04 How We Collect Your Data
We collect Personal Data through the following means:
- Directly from you: When you register an Account, complete the KYC process, make deposits or withdrawals, participate in promotions, or contact our support team;
- Automatically: Through cookies, server logs and similar technologies when you browse or interact with the Platform;
- From third-party service providers: Identity verification agencies, payment processors and fraud-detection services may provide data to us in connection with Account security and compliance obligations. References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are provided as familiar local payment context — their inclusion does not indicate a data-sharing partnership with those institutions;
- From public sources: Publicly available information such as sanction lists and politically exposed persons (PEP) databases may be consulted as part of compliance checks.
05 Legal Basis for Processing
Where applicable data protection law requires us to identify a legal basis for processing, we rely on the following grounds:
06 How We Use Your Personal Data
zk77 uses collected Personal Data for the following purposes:
- Account management: To create, maintain and administer your Account, verify your identity, and authenticate your login sessions;
- Service delivery: To process bets, settle wagers, credit bonuses, execute deposits and withdrawals in PKR, and provide all Platform features;
- Compliance and legal obligations: To meet anti-money laundering (AML), know-your-customer (KYC) and other regulatory requirements applicable under the Platform's operating licence;
- Fraud and security: To detect, prevent and investigate fraudulent activity, account takeovers, bonus abuse, underage gambling and other prohibited conduct;
- Responsible gambling: To monitor player activity for signs of problem gambling behaviour and to administer deposit limits, self-exclusion and other player protection tools;
- Customer support: To respond to queries, process complaints and maintain a record of our communications with you;
- Marketing (with consent): To send you promotional communications about Platform offers, new features and relevant sports markets (e.g., upcoming PSL fixtures, ICC tournaments) where you have opted in. You may opt out at any time;
- Platform improvement: To analyse usage patterns, identify technical issues and improve the overall user experience.
No selling of data: zk77 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. Data is shared only as described in Section 7 of this Policy.
07 Data Sharing & Third-Party Disclosure
We share your Personal Data only where necessary and only with the categories of recipients described below. All third-party Data Processors are subject to contractual data protection obligations consistent with this Policy.
- Identity verification providers: Third-party KYC and AML service providers who assist in verifying your identity and checking relevant compliance databases;
- Payment processors: Entities that facilitate deposit and withdrawal transactions on the Platform. Only the minimum data necessary for the transaction is shared;
- Technology and hosting providers: Cloud infrastructure, content delivery and data storage providers who host Platform data under contractual security obligations;
- Customer support platforms: Third-party tools used to manage live chat and email support communications;
- Analytics providers: Service providers that help us analyse Platform usage in aggregate or pseudonymous form to improve performance;
- Legal and regulatory bodies: Where required by applicable law, court order, or regulatory direction, we may be obligated to disclose Personal Data to law enforcement, financial regulators or other competent authorities. We will notify you of such disclosures where legally permissible;
- Business transfers: In the event of a merger, acquisition or sale of all or part of our business assets, Personal Data held by zk77 may be transferred to the acquiring entity, subject to equivalent data protection obligations.
08 Cookies & Tracking Technologies
zk77 uses cookies and similar technologies to ensure the Platform functions correctly, to maintain your session while logged in, and to understand how users interact with different features. The categories of cookies we use are as follows:
- Strictly necessary cookies: Essential for the Platform to operate. These include session authentication cookies, security tokens and load-balancing cookies. They cannot be disabled without severely impairing Platform functionality.
- Functional cookies: Remember your preferences, such as language settings and previously selected payment method, to improve convenience on return visits.
- Analytics cookies: Collect aggregated or pseudonymous data about page views, session duration and navigation paths to help us understand usage patterns and improve the Platform. No individually identifying information is transmitted to analytics providers through these cookies.
- Security cookies: Support fraud detection, bot mitigation and suspicious login activity identification.
Cookie Management: You may adjust cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use core Platform features. Disabling analytics cookies will not affect your ability to use the Platform.
09 Data Retention
We retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal minimum retention requirements. Our general retention approach is as follows:
- Active Account data: Retained for the duration of your Account's existence on the Platform plus a defined period following Account closure, to satisfy AML, KYC and dispute resolution obligations;
- KYC documentation: Retained for a minimum period as required by the applicable licensing regime and AML regulations. Typical minimum retention periods range from five to seven years following Account closure, though this may vary;
- Transaction records: Retained for the minimum period required under applicable financial record-keeping obligations following the date of each transaction;
- Support and complaint records: Retained for a reasonable period following resolution of the relevant matter, to support any subsequent dispute or appeal;
- Marketing data: Retained until you withdraw consent or opt out of marketing communications, at which point your data is removed from active marketing lists.
Data that is no longer required for the purposes described above and which is not subject to a legal retention obligation will be securely deleted or anonymised.
10 Data Security
zk77 implements technical and organisational security measures designed to protect Personal Data against unauthorised access, loss, alteration or destruction. These measures include:
- Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers;
- Encryption of sensitive data fields at rest, including payment instrument details and identity document copies;
- Access controls that restrict Personal Data access to authorised personnel with a legitimate operational need;
- Regular internal security reviews and monitoring for suspicious access patterns;
- Two-factor authentication (2FA) options for User Account access.
Your responsibilities: No security system is completely impenetrable. You are responsible for maintaining the confidentiality of your Account credentials and for notifying us immediately if you suspect unauthorised access. Do not share your password with any third party. Do not access zk77 over unsecured public Wi-Fi networks without additional protection.
11 International Data Transfers
zk77 operates internationally and may transfer your Personal Data to servers, Data Processors or affiliated entities located in jurisdictions outside Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place, consistent with applicable data protection standards. These safeguards may include:
- Contractual clauses that bind Data Processors to data protection obligations equivalent to those described in this Policy;
- Transfer to jurisdictions that the relevant licensing authority considers to offer an adequate level of data protection;
- Pseudonymisation or anonymisation of data where possible before transfer.
By using the Platform, you acknowledge that your Personal Data may be processed in jurisdictions outside Pakistan and that different data protection standards may apply in those jurisdictions.
12 Your Data Rights
Subject to applicable law and the conditions of our operating licence, you have the following rights in relation to your Personal Data. Requests should be submitted in writing to our support team using the contact details in Section 15.
You have the right to request a copy of the Personal Data we hold about you. We will respond to verified access requests within a reasonable timeframe as required by applicable law.
If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update some Account details directly through your Account settings.
You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected. This right does not apply where retention is required by law (e.g., AML and KYC records subject to minimum statutory retention periods).
You may request that we restrict the processing of your Personal Data in defined circumstances, for example while a rectification request is being assessed or pending the outcome of an objection.
Where processing is based on your consent or on a contractual basis, and is carried out by automated means, you may request that your Personal Data be provided to you in a structured, commonly used and machine-readable format.
You have the right to object to processing based on our legitimate interests or for direct marketing purposes. Where we are processing your data for direct marketing, we will comply with an objection immediately.
Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time by updating your Account preferences or contacting our support team. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
How to exercise your rights: Submit a written request to our support team at [email protected]. We may require you to verify your identity before processing any data rights request to protect against fraudulent or unauthorised claims.
13 Children & Minors
The zk77 Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required under applicable law or the Platform's operating licence conditions, whichever is greater. We do not knowingly collect Personal Data from individuals under this age threshold.
If we become aware that Personal Data has been collected from an underage individual, we will take immediate steps to delete that data, close the associated Account, and return any deposits made in accordance with our standard fraud and underage registration review procedures.
Parents and guardians who believe that a minor in their care may have registered on the Platform are encouraged to contact our support team immediately so that the matter can be investigated and resolved promptly.
18+ Only: Being 18 years of age does not, by itself, make online gambling lawful in Pakistan. Users are solely responsible for understanding and complying with the laws applicable to them in their jurisdiction.
14 Policy Amendments
zk77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or Platform operations. When material changes are made, we will notify registered Users by posting a prominent notice on the Platform or by email to the address registered with your Account.
The "Document version" date at the top of this page indicates when the Policy was last reviewed. Your continued use of the Platform following notification of an updated Policy constitutes acceptance of the revised terms. If you do not accept any amendments, you should cease using the Platform and may request Account closure.
15 Contact Us & Data Complaints
If you have any questions about this Privacy Policy, wish to exercise a data right, or wish to raise a complaint about our data practices, please contact our support team using the details below. All data rights requests and privacy complaints must be submitted in writing and will be acknowledged with a reference number.
Data Privacy Enquiries & Complaints:
Email: [email protected]
Live Chat: Available 24/7 via the Help Center on the Platform. For formal data rights requests, please use email so that a written record is maintained.
Please include "Data Rights Request" or "Privacy Complaint" in the subject line of your email, along with your registered Account username, to help us process your request efficiently.
For further context on how we use your data within the broader Platform framework, please review our Terms & Conditions and our Responsible Gambling page.