Table of Contents
1. Introduction 2. Definitions 3. Data We Collect 4. How We Collect Data 5. Data Processing Purposes 6. Legal Basis for Processing 7. Data Sharing & Disclosure 8. Cookies & Tracking 9. Data Retention 10. Security Measures 11. User Rights 12. Minors & Age Restrictions 13. Third-Party References 14. Amendments to This Policy 15. Contact Us1 Introduction
This Privacy Policy ("Policy") describes how zh77 ("zh77", "we", "us", "our"), the operator of the website located at zh77.cam (the "Platform"), collects, uses, stores, discloses and protects personal information in connection with the use of this Platform.
zh77 is an independent, English-language information and guide platform. We serve users — primarily in Pakistan and its cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — who are seeking educational content about online betting, casino gaming, payments and responsible gambling practices. We are not a gambling operator, do not process wagers and hold no Pakistani gambling licence.
We are committed to handling all personal information with transparency, integrity and appropriate security. This Policy applies to all users of the Platform ("User", "you", "your") regardless of how they access the site — via desktop, mobile browser or any other means.
By using the Platform, you confirm that you have read and understood this Policy. If you do not agree with our data practices as described here, please discontinue use of the Platform immediately.
This Policy should be read in conjunction with zh77's Terms & Conditions, which govern your overall use of the Platform.
2 Definitions
The following terms carry the meanings assigned to them below throughout this Policy:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information that identifies or could reasonably identify a living individual, including name, email address, IP address and device identifiers. |
| "Processing" | Any operation performed on personal data — including collection, storage, use, transmission, alteration or deletion. |
| "Data Controller" | zh77 — the entity that determines the purposes and means by which personal data is processed. |
| "Data Processor" | A third party that processes personal data on behalf of zh77 under a written instruction — such as hosting providers or analytics services. |
| "Cookies" | Small text files placed on a user's device by a web browser to store preferences, session identifiers or analytical data. |
| "Consent" | A freely given, specific, informed and unambiguous indication of a user's agreement to the processing of their personal data for a stated purpose. |
| "Platform" / "Site" | The zh77 website and all pages accessible at zh77.cam. |
| "Third-Party Operator" | Any external gambling service provider referenced in Platform content for informational context. zh77 is not a gambling operator. |
3 Data We Collect
3.1 Data You Provide Directly
As zh77 is an informational platform and does not require user registration, we do not routinely collect name, address, date of birth or financial information. However, personal data may be provided voluntarily in the following circumstances:
- Contact enquiries: If you email us at [email protected], we collect the email address you send from, together with the content of your message and any attachments you include.
- Feedback or support requests: Where you submit a query or feedback via any on-site contact mechanism, the information you enter (e.g., name, email address, message content) is collected.
3.2 Data Collected Automatically
When you visit the Platform, certain data is collected automatically through standard web technologies:
| Data Type | Examples | Purpose |
|---|---|---|
| IP Address | 213.147.x.x (Pakistan-based) | Security, fraud prevention, geographic analytics |
| Device & Browser | Browser type, OS version, screen resolution | Platform optimisation and compatibility |
| Usage Data | Pages visited, time on page, referral URL | Content improvement, editorial prioritisation |
| Session Data | Session duration, navigation path | User experience improvement |
| Cookie Data | Preference cookies, session cookies, analytics identifiers | See Section 8 (Cookies) for full detail |
We do not collect sensitive personal data — including biometric data, health information, religious beliefs or financial account details — through this Platform.
4 How We Collect Data
zh77 collects personal data through the following mechanisms:
- Direct communication: When you contact us by email or any on-site contact mechanism, personal data is collected as part of that communication.
- Automatic web technologies: Server logs, browser cookies and analytics scripts automatically record interaction data when you load any page of the Platform.
- Analytics services: We may use industry-standard web analytics tools to collect aggregated, anonymised or pseudonymised usage statistics. These tools operate as data processors under our instruction.
- Security systems: Our hosting infrastructure may log IP addresses and request metadata for security, DDoS protection and abuse prevention purposes.
5 Data Processing Purposes
zh77 processes personal data only for the following legitimate purposes:
| Purpose | Description | Data Used |
|---|---|---|
| Platform Operation | Delivering, maintaining and improving the technical functioning of the Platform for all users | IP address, session data, device data |
| Content Improvement | Understanding which guides, payment articles and responsible gambling content are most useful to Pakistani users | Aggregated usage and navigation data |
| Security & Integrity | Detecting, investigating and preventing malicious activity, bot traffic, scraping and abuse | IP address, request logs, session data |
| Responding to Enquiries | Handling questions, feedback and support requests submitted to zh77 | Email address, message content |
| Legal Compliance | Meeting any legal obligation that requires us to retain or disclose data | As required by the specific obligation |
| Analytics | Generating aggregated, anonymised statistics about Platform usage to inform editorial decisions | Pseudonymised usage data, cookie identifiers |
We do not process personal data for direct marketing, behavioural advertising, profiling for commercial purposes, or resale to third parties under any circumstances.
6 Legal Basis for Processing
Where applicable data protection law requires a legal basis for processing personal data, zh77 relies on the following bases:
6.1 Legitimate Interests
The processing of automatically collected data (IP address, device data, usage logs) is carried out on the basis of zh77's legitimate interest in operating, maintaining and improving a secure, functional information platform. This processing does not override users' fundamental privacy rights.
6.2 Consent
Where non-essential cookies or analytics tools are deployed, such processing is carried out on the basis of your consent, expressed through your continued use of the Platform after appropriate notice. You may withdraw consent by adjusting your browser settings to block or delete cookies — see Section 8 for detail.
6.3 Contractual Necessity
Where you contact zh77 directly with a support query or feedback, processing your email address and message content is necessary to respond to your communication.
6.4 Legal Obligation
In limited circumstances, zh77 may be required to process or disclose personal data to comply with a legal obligation — such as a court order or regulatory requirement issued by a competent authority.
7 Data Sharing & Disclosure
7.1 No Sale of Personal Data
zh77 does not sell, rent, trade or otherwise commercially transfer personal data to any third party for their own marketing or commercial purposes. This is an absolute commitment, not a policy subject to exceptions based on commercial value.
7.2 Service Providers (Data Processors)
zh77 may engage trusted third-party service providers who act as data processors on our behalf. These include:
- Web hosting providers: to store and serve the Platform's files and databases;
- Content delivery network (CDN) services: to optimise Platform loading speed, including for users in Karachi, Lahore, Islamabad and other Pakistani cities;
- Analytics tools: to generate anonymised usage reports;
- Security services: to protect against DDoS attacks, malicious bots and other threats.
All data processors are engaged under contractual terms that restrict their use of your data to the specific service they provide to zh77, prohibit independent use of your data and require appropriate security measures.
7.3 Legal Disclosure
zh77 may disclose personal data if required to do so by applicable law, court order, regulatory direction or to protect the rights, property or safety of zh77, its users or the public. We will make reasonable efforts to notify affected users where legally permissible before such disclosure.
7.4 Business Transfers
In the event of a merger, acquisition, restructuring or sale of all or part of zh77's assets, personal data held by zh77 may be transferred to the acquiring entity. Users will be notified of any such transfer via a prominent update to this Policy.
7.5 Gambling Operator References
zh77 does not share user data with gambling operators referenced in its content. References to operators, payment providers (including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) or sports organisations are made in editorial text only and do not involve any transfer of user data to those parties.
8 Cookies & Tracking Technologies
8.1 What Are Cookies
Cookies are small text files stored on your device by your web browser when you visit a website. They allow the site to recognise your device on subsequent visits and store certain preferences or session data.
8.2 Cookies zh77 Uses
| Cookie Type | Purpose | Duration | Category |
|---|---|---|---|
| Session Cookies | Maintain your browsing session while you navigate between pages | Session (deleted on browser close) | |
| Preference Cookies | Remember display preferences such as collapsed navigation state | Up to 12 months | |
| Analytics Cookies | Collect anonymised or pseudonymised data about page views, session duration and navigation paths to improve content | Up to 24 months | |
| Security Cookies | Help identify and mitigate automated bot traffic, scraping and security threats | Session to 30 days |
8.3 Managing Cookies
You can control and manage cookies in several ways:
- Browser settings: All major browsers allow you to view, block or delete cookies through their settings menus. Blocking essential cookies may affect Platform functionality.
- Incognito / private browsing: Using private browsing mode limits persistent cookie storage on your device.
- Opt-out of analytics: Most analytics providers offer browser opt-out mechanisms. Consult the provider's documentation for specific instructions.
Disabling all cookies may affect how certain elements of the Platform display or function but will not prevent you from accessing the site's editorial content.
8.4 No Cross-Site Advertising Tracking
zh77 does not use advertising cookies, retargeting pixels or cross-site tracking technologies that build a profile of your browsing activity across other websites for advertising purposes.
9 Data Retention
zh77 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, subject to any applicable legal obligation to retain data for a longer period.
| Data Type | Retention Period | Basis |
|---|---|---|
| Server log / IP data | Up to 90 days | Security monitoring, abuse investigation |
| Analytics data (anonymised) | Up to 26 months | Trend analysis and content improvement |
| Email correspondence | Up to 24 months from last interaction | Support continuity, dispute resolution |
| Cookie data (analytics) | Up to 24 months | Usage analytics as described in Section 8 |
| Legal / compliance records | As required by applicable law | Legal obligation |
Once the relevant retention period expires, personal data is securely deleted or irreversibly anonymised. Users may request early deletion of their data, subject to the provisions in Section 11.
10 Security Measures
10.1 Technical Safeguards
zh77 implements industry-standard technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration or disclosure. These include:
- HTTPS / TLS encryption for all data in transit between your browser and our servers;
- Access controls limiting personal data access to authorised personnel only;
- Regular security reviews of Platform infrastructure;
- DDoS protection and web application firewall (WAF) measures;
- Secure, access-controlled server environments with hosting providers subject to data processor obligations.
10.2 Limitations
No method of transmission over the internet or electronic storage is completely secure. Whilst zh77 takes all reasonable steps to protect your personal data, we cannot guarantee absolute security. In the unlikely event of a data breach that affects your rights or freedoms, we will notify affected users and relevant authorities as required by applicable law.
10.3 User Responsibilities
If you contact zh77 by email, you are responsible for the security of your own email account and device. Do not transmit highly sensitive personal information (such as CNIC numbers, bank account details or passwords) via email communications with zh77.
11 User Rights
Subject to applicable data protection law, you have the following rights regarding personal data that zh77 holds about you. To exercise any of these rights, contact us at [email protected] with a clear description of your request.
Right of Access
You may request a copy of the personal data zh77 holds about you, together with information about how it is used and with whom it is shared.
Right of Rectification
If personal data zh77 holds about you is inaccurate or incomplete, you have the right to request correction. We will action verified correction requests promptly.
Right of 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 legal retention obligations.
Right to Restrict Processing
In certain circumstances, you may request that we restrict the processing of your data — for example, while the accuracy of data is being contested.
Right to Object
Where processing is based on legitimate interests, you have the right to object. We will assess your objection and cease processing unless compelling legitimate grounds exist.
Right to Data Portability
Where technically feasible and legally required, you may request that personal data you have provided be supplied in a structured, machine-readable format.
We aim to respond to all valid rights requests within 30 days. Where a request is complex or numerous, we may extend this period by a further 60 days with notice. We may need to verify your identity before processing a rights request. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive.
12 Minors & Age Restrictions
The Platform is intended exclusively for users aged 18 and over, or the higher minimum age required by the relevant operator's licence jurisdiction. zh77 does not knowingly collect personal data from individuals under 18 years of age.
If we become aware that personal data has been collected from a minor, we will take prompt steps to delete that data. If you believe a minor has submitted personal data to zh77, please contact us immediately at [email protected].
Parents and guardians are responsible for supervising minors' internet access. We encourage the use of parental control software where minors may access devices on which the Platform has been visited.
13 Third-Party References & External Privacy
13.1 No Responsibility for Third-Party Privacy Practices
zh77's content references third-party gambling operators, payment providers and services for informational context. These references do not create any data-sharing relationship between zh77 and those entities. zh77 is not responsible for the privacy practices of any third party mentioned in its content.
13.2 Payment Provider References
Names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah appear in zh77's editorial content as familiar payment references for Pakistani users. Their appearance does not imply any data-sharing agreement, endorsement or affiliation between those providers and zh77 or any gambling operator. If you use any of these services, your data is governed by their own privacy policies.
13.3 CDN & Infrastructure Providers
zh77 uses third-party CDN and infrastructure services (such as those delivering Bootstrap CSS and JavaScript libraries referenced in the Platform's code). These services may process your IP address and request data as part of content delivery. They operate as data processors under standard industry terms. For users in Pakistan, CDN routing may involve nodes in multiple geographic locations to optimise performance.
13.4 No External Links to Gambling Sites
zh77 does not include clickable external links to gambling operator websites. Accordingly, there is no mechanism on this Platform through which your browsing data would be passed to an operator as a referral.
14 Amendments to This Policy
14.1 Right to Update
zh77 reserves the right to update this Privacy Policy at any time to reflect changes in data practices, applicable law, or Platform functionality. The revised Policy will be published at zh77.cam/privacy-policy with an updated "Last reviewed" date.
14.2 Notification of Material Changes
Where amendments are material — for example, if zh77 were to introduce a new category of data collection or change the basis on which data is shared — we will make reasonable efforts to highlight such changes prominently on the Platform.
14.3 Continued Use as Acceptance
Your continued use of the Platform after any Policy update constitutes your acknowledgement of the revised Policy. If you do not accept the revised terms, please discontinue using the Platform and contact us to request deletion of any personal data we hold.
15 Contact Us — Data & Privacy Enquiries
For any questions, concerns or requests relating to this Privacy Policy or zh77's data practices, please contact us using the details below. We take all privacy enquiries seriously and will respond in a timely and transparent manner.
When submitting a rights request (access, erasure, portability etc.), please describe the specific data you are enquiring about and how you believe it was collected by zh77. This helps us locate and process your request accurately. We may need to verify your identity before acting on a request — this is a standard security measure to protect your data, not an obstacle.
Six Privacy Commitments zh77 Makes to You
A plain-English summary of the six things that matter most about how zh77 handles data.
We Never Sell Your Data
Personal data zh77 collects is never sold, rented or traded to third parties for their marketing or commercial use — under any circumstances or for any commercial consideration.
Secure by Design
All data in transit is protected by HTTPS/TLS encryption. Server access is restricted, and infrastructure security is reviewed regularly. Your information is treated with the same care as any sensitive financial platform.
No Ad Tracking
zh77 does not deploy advertising networks, retargeting pixels or cross-site behavioural tracking. Your browsing on this Platform stays on this Platform — it is not shared with advertisers.
Your Rights Are Real
Access, correction, deletion, portability — zh77 treats user rights as genuine obligations, not formalities. Contact us and we will respond within 30 days with a substantive answer.
Minimal Retention
We keep data only as long as necessary for the purpose it was collected. Server logs are purged within 90 days. Analytics data is anonymised. We do not hoard personal data beyond its useful operational life.
Plain English Always
This Policy is written in clear, professional English accessible to Pakistani users — not buried in legal jargon designed to obscure obligations. Transparency is zh77's editorial standard across all content, including legal documents.