Privacy Policy — zhgame

zhgame ("we", "us", "our") operates the informational and entertainment platform accessible at https://zhgame.cam (the "Platform"). This Privacy Policy ("Policy") sets out how zhgame collects, uses, discloses, stores and protects personal data relating to users ("you", "your") of this Platform, in accordance with applicable data protection principles.

This Policy applies to all personal data processed in connection with your access to and use of the Platform. It covers data collected directly from you, data generated by your use of the Platform and data received from third-party sources where applicable.

By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with our data practices as described, you should discontinue use of the Platform. This Policy should be read alongside our Terms & Conditions, which governs your overall use of zhgame.

For the purposes of this Policy, the Data Controller responsible for personal data collected through the Platform is:

All data-related enquiries, requests and complaints should be directed to the contact address above. We aim to acknowledge all written data requests within a reasonable timeframe and to resolve them in accordance with Applicable Law.

zhgame collects personal data in the following categories, depending on how you interact with the Platform:

zhgame processes personal data for the following specific purposes:

• Platform Operation: To deliver, maintain and improve the functionality, content and performance of the Platform for users in Pakistan and other jurisdictions.
• Analytics & Improvement: To understand how users interact with the Platform — which pages are most visited, how navigation flows work, and where content improvements are needed. Analytics data is processed in aggregated or anonymised form where possible.
• Communication: To respond to enquiries, support requests, feedback submissions and any other communications you send to zhgame. Communication data is used only to handle your query and maintain a record of our correspondence.
• Security: To detect, investigate and prevent fraudulent activity, unauthorised access, technical abuse or other security threats to the Platform.
• Legal Compliance: To comply with applicable legal obligations, including responding to lawful requests from regulatory or law enforcement authorities where required.
• Cookie Functionality: To remember your preferences, maintain session integrity and provide a consistent user experience across visits.

We do not process your personal data for direct marketing purposes, behavioural advertising, credit assessment, profiling for gambling purposes or any purpose not listed above.

For each category of personal data we process, we rely on at least one of the following lawful bases:

• Legitimate Interests: Processing technical and usage data to operate, maintain and improve this informational platform represents a legitimate interest of zhgame that is balanced against the rights and interests of users. We conduct proportionality assessments to ensure this balance is maintained.
• Consent: Where we rely on your consent to place non-essential cookies or process optional data categories, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Contractual Necessity: Where you have entered into a relationship with zhgame (for example, by submitting an enquiry), processing your communication data to respond is necessary to perform that interaction.
• Legal Obligation: Where we are required by applicable law to retain or disclose certain data, we will do so in compliance with that obligation.

zhgame does not sell, rent, trade or otherwise transfer your personal data to third parties for their own commercial purposes. We may share personal data in the following limited circumstances only:

• Service Providers (Data Processors): We engage trusted technical service providers — such as hosting providers, analytics platforms and security services — who process data on our behalf under strict contractual obligations. These providers are not permitted to use your data for their own purposes.
• Legal Requirements: We may disclose personal data if required to do so by applicable law, court order or lawful request from a competent public authority — including law enforcement or regulatory bodies — provided that such request is made through legally valid channels.
• Business Continuity: In the event of a merger, acquisition or transfer of zhgame's assets, personal data may be transferred to the successor entity subject to equivalent data protection obligations. Users will be notified of any such transfer via an update to this Policy.
• Aggregated Data: We may share anonymised, aggregated usage statistics that cannot identify any individual user for research, reporting or platform improvement purposes.

We retain personal data only for as long as reasonably necessary to fulfil the purpose for which it was collected, or as required by Applicable Law. Our general retention approach is as follows:

• Technical & Usage Data: Retained in aggregated or anonymised form for up to 26 months for analytics purposes, after which it is deleted or further anonymised.
• Communication Data: Email correspondence and support records are retained for up to 24 months from the date of last contact, unless a longer period is required to resolve an ongoing matter or legal obligation.
• Cookie Data: Session cookies are deleted when you close your browser. Persistent cookies are retained for the period defined in our cookie settings, not exceeding 12 months unless renewed by a return visit.
• Security Logs: Data collected for fraud prevention and security monitoring is retained for up to 12 months from collection, unless a specific investigation requires longer retention.

When data is no longer required, it is securely deleted or rendered permanently anonymous in line with our data deletion procedures. You may request earlier deletion of your personal data by contacting us — see Section 9 and Section 16 below.

Depending on applicable data protection law and your jurisdiction, you may have the following rights in relation to your personal data held by zhgame. To exercise any of these rights, please contact us at the address in Section 16.

We will respond to all valid data subject requests within a reasonable timeframe and in accordance with Applicable Law. We may need to verify your identity before processing a request. We do not charge a fee for routine requests unless a request is manifestly unfounded or excessive.

zhgame uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that enable us to recognise your browser on return visits and to understand how users navigate the Platform.

We use the following categories of cookies:

We do not use advertising cookies, cross-site tracking cookies or cookies that share data with third-party advertisers. You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform. Continued use of the Platform following cookie notice acknowledgement implies acceptance of our functional and analytics cookies.

zhgame implements industry-standard technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, disclosure or alteration. Our security measures include:

• TLS encryption for all data transmitted between your browser and the Platform;
• Encryption of personal data stored in our systems;
• Access controls that restrict personal data access to authorised personnel only;
• Regular security assessments of our systems and service providers;
• Procedures to detect, investigate and respond to suspected data security incidents.

Despite these measures, no internet transmission or electronic storage system is entirely secure. Users in Pakistan — particularly those accessing the Platform over public networks in cities such as Karachi, Lahore or Islamabad — should take reasonable precautions such as using secure, private connections and keeping browsers updated.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, zhgame will take appropriate steps in line with applicable data breach notification requirements.

The zhgame Platform is intended exclusively for adults aged 18 years and above — or the higher minimum age required by the relevant operator's licensing jurisdiction. We do not knowingly collect, process or retain personal data from individuals under the age of 18.

If we become aware that personal data has been submitted by a person under 18, we will take prompt steps to delete that data from our records. If you believe that a minor has submitted personal data to zhgame, please contact us immediately at the address in Section 16.

Some of the technical service providers we use to operate the Platform may be located outside Pakistan. This means that personal data we collect may be transferred to, and processed in, countries outside Pakistan.

Where such transfers occur, we take reasonable steps to ensure that the receiving entity provides an adequate level of data protection — including through contractual safeguards, standard contractual clauses or other appropriate mechanisms recognised under applicable data protection law.

Pakistani users should be aware that data protection laws in other countries may differ from those applicable in Pakistan. By using this Platform, you acknowledge that your data may be processed in other jurisdictions for the purposes described in this Policy.

The Platform may contain references to third-party operators, services and organisations for informational context. zhgame does not include active outbound links to external websites in the body of its pages as a matter of policy. However, where operator names, payment providers or organisations are mentioned by name, those entities have their own independent privacy policies that are entirely outside the scope of this document.

zhgame is not responsible for the privacy practices, data handling or content of any third-party operator or service referenced on this Platform. Users who choose to engage directly with third-party operators do so under those operators' own terms and privacy policies, which should be reviewed independently before sharing any personal data.

zhgame reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform functionality. When we make material changes to this Policy, we will update the "Last Updated" date displayed at the top of this page.

We encourage you to review this Policy periodically to stay informed of how we handle your personal data. Your continued use of the Platform following any update constitutes acceptance of the revised Policy. If the changes are significant and you do not agree, you should discontinue your use of the Platform and may contact us to request deletion of your personal data.

If you wish to exercise any of your data subject rights, have questions about this Privacy Policy, or wish to raise a data-related complaint, please contact zhgame using the details below. All communications should be submitted in English.

We aim to acknowledge all privacy-related communications within a reasonable timeframe. Complex requests involving data access, deletion or portability may take longer to process fully. We will keep you informed of progress.

If you are dissatisfied with our response to a privacy complaint, you may have the right to escalate the matter to the competent data protection supervisory authority in your jurisdiction. We are committed to working cooperatively with such authorities to resolve complaints in accordance with Applicable Law.