Privacy Policy

1. Overview

This Privacy Policy ("Policy") describes how za22 ("za22", "we", "us", "our") — the operator of the online gaming platform at za22.app — collects, processes, stores, and protects the personal information of its registered users and website visitors, with particular reference to players based in Pakistan.

By registering an account on za22, depositing funds, placing wagers, or simply browsing the za22 platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. This Policy forms part of and should be read alongside our Terms & Conditions.

2. Data Controller

za22 acts as the data controller in respect of all personal data collected through the za22.app platform. As data controller, za22 determines the purposes and means of processing your personal information and is responsible for ensuring that such processing complies with applicable data protection principles.

For all data-related queries, requests, or complaints, the designated point of contact is the za22 Data Protection team, reachable via the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

za22 collects personal data in the following categories, depending on how you interact with our platform:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth (used exclusively for age verification — you must be 21 or older)
• National Identity Card (CNIC) number, where required for KYC verification
• Email address and mobile phone number
• Residential address (city, district, province — Pakistan)
• Username and encrypted password hash

3.2 Financial & Transaction Data

• Payment method details (JazzCash account number, EasyPaisa number, bank account references for HBL, UBL, Meezan Bank, or card BIN data)
• Deposit and withdrawal transaction history, including amounts in PKR and timestamps
• Bonus claims, wagering activity, and win/loss records

3.3 Technical & Usage Data

• IP address and approximate geolocation at time of access
• Device type, operating system, and browser information
• Session duration, pages visited, and clickstream data
• Game logs, bet histories, and platform interaction records

3.4 Communications Data

• Records of support interactions via live chat, email, or any other channel
• Feedback, survey responses, and promotional opt-in preferences

4. How We Collect Your Data

za22 collects personal data through the following methods:

• Direct Collection: Information you provide when registering, completing KYC verification, making deposits, contacting support, or participating in promotions.
• Automated Collection: Technical data gathered automatically via cookies, log files, and analytics tools when you access za22.app (see Section 10 for our full Cookie Policy).
• Third-Party Sources: Identity verification agencies and payment processors may confirm or supplement data you have provided, strictly for fraud prevention and compliance purposes.

5. How We Use Your Data

za22 processes your personal data only for legitimate, clearly defined purposes. The table below summarises the primary purposes for which your data is used and the corresponding legal basis for each:

6. Legal Basis for Processing

za22 processes your personal data on one or more of the following legal bases, depending on the nature of the processing activity:

• Contractual Necessity: Processing required to fulfil our obligations to you under the za22 Terms & Conditions — such as account creation, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable anti-money laundering (AML), know-your-customer (KYC), and responsible gaming regulations.
• Legitimate Interest: Processing conducted for za22's legitimate business interests, including fraud detection, platform security, and service improvement — provided such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — for example, receiving marketing communications or promotional emails. You may withdraw consent at any time by contacting support or updating your account preferences.

7. Data Sharing & Third Parties

za22 does not sell your personal data. We may share your information with carefully selected third parties only where necessary and under strict data protection agreements. Categories of recipients include:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card processing networks — to facilitate deposits and withdrawals in PKR. These providers receive only the minimum financial data required to complete transactions.
• Identity Verification Providers: Third-party KYC and AML compliance services that assist in verifying your identity and preventing financial crime. These providers are contractually bound to handle your data securely.
• Game Software Providers: Licensed game studios whose products are hosted on the za22 platform may receive anonymised session and gameplay data for auditing and fairness verification purposes.
• Analytics Providers: Platform analytics tools used to understand user behaviour and improve our services. Data shared with analytics providers is aggregated or pseudonymised wherever possible.
• Regulatory & Legal Authorities: Where required by law, court order, or legitimate regulatory request, za22 may disclose personal data to competent authorities. We will notify you of such disclosures where legally permitted to do so.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring of za22's business, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

8. Data Retention

za22 retains your personal data only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any individual.

9. Security Measures

za22 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-Bit SSL Encryption: All data transmitted between your device and za22 servers is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Encrypted Data Storage: Sensitive data at rest, including financial records and identity documents, is stored in encrypted format on access-controlled servers.
• Access Controls: Strict role-based access controls limit which za22 staff members can access personal data. All access is logged and audited regularly.
• Two-Factor Authentication: Account access can be secured with two-factor authentication, which we strongly recommend all za22 players enable.
• Penetration Testing: za22's systems undergo regular security assessments and penetration testing by independent cybersecurity professionals.
• Incident Response: In the event of a data breach that poses a risk to your rights and freedoms, za22 will notify affected users and relevant authorities within the timeframes required by applicable law.

10. Cookies & Tracking Technologies

za22 uses cookies and similar tracking technologies to operate the platform, remember your preferences, and understand how users interact with our site. The following cookie categories are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication tokens and security cookies. They cannot be disabled without affecting your ability to use za22.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and display options to personalise your za22 experience.
• Analytics Cookies: Help us understand how players navigate the platform, which pages are most visited, and where technical issues arise. Data collected is aggregated and does not identify you personally.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content. You can withdraw this consent at any time through your account settings.

You can manage or disable non-essential cookies at any time via your browser settings. Please note that disabling certain cookies may affect the functionality of the za22 platform. A full cookie consent tool is available in the za22 account settings panel.

11. Your Data Rights

As a za22 user, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us using the details in Section 14:

• Right of Access: You may request a copy of all personal data za22 holds about you, free of charge, within 30 days of your request.
• Right to Rectification: If any of your personal data held by za22 is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations detailed in Section 8.
• Right to Restriction of Processing: You may request that za22 restrict the processing of your data in certain circumstances, such as while a data accuracy dispute is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on za22's legitimate interests, including direct marketing communications. We will cease such processing unless we can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

za22 will respond to all verified data rights requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days, and you will be informed of the extension within the initial 30-day period.

12. Minors & Age Policy

za22 is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from any person under the age of 21. Age verification is conducted as part of the mandatory KYC process for all registered accounts.

If za22 discovers or is notified that personal data has been collected from a person under the age of 21, we will immediately:

• Suspend and permanently close the relevant account;
• Refund any deposited funds to the originating payment method;
• Delete all personal data associated with the underage user from our systems, subject to any overriding legal retention requirements.

13. Changes to This Policy

za22 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, za22 will notify registered users via email or a prominent notice on the platform at least seven (7) days before the revised Policy takes effect.

The "Effective Date" at the top of this Policy will be updated each time a new version is published. We encourage you to review this Policy periodically. Your continued use of za22 after the effective date of any revised Policy constitutes your acceptance of the updated terms.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the za22 Data Protection team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the in-platform support widget on za22.app
• Response Time: Data rights requests acknowledged within 5 business days; full response within 30 calendar days (PKT)
• Business Hours: 8:00 AM – 12:00 AM PKT, seven days a week

If you have concerns about our responsible gaming practices, please visit our dedicated Responsible Gaming Policy page.