Privacy Policy

Effective Date: 14 July 2026
Last Updated: 6 August 2026
Company: SunZee1 (Private) Limited
SECP UIN: 0345458

Introduction

At SunZee1, we believe that your privacy is not a checkbox — it is a responsibility. This Privacy Policy explains in plain, clear language exactly what personal information we collect from you, why we collect it, how we use it, who we share it with, and what rights you have over your own data.

Please read this policy carefully before using the SunZee1 platform at sunzee1.com or the SunZee1 Progressive Web App. By registering an account or using our services in any capacity, you confirm that you have read, understood, and agreed to the practices described in this Privacy Policy.

If you do not agree with any part of this policy, please discontinue use of the platform and contact us at privacy@sunzee1.com to request account deletion.

1. Who We Are

SunZee1 (Private) Limited is a private company limited by shares, incorporated under the Companies Act, 2017, and registered with the Securities and Exchange Commission of Pakistan (SECP) under Corporate UIN 0345458.

Our registered office is located at:

Office No. 101, 1st Floor
22 Industrial Estate
Bahawalnagar, Punjab, Pakistan

Our US affiliate, SunZee1 LLC, operates at:

4539 N 22nd St, Ste B
Phoenix, AZ 85016, USA

For all privacy-related inquiries, contact us at: privacy@sunzee-1.pk

2. Information We Collect

We collect only the information that is necessary to operate the platform securely, process your investments, distribute your earnings, and comply with our legal obligations. We do not collect data for the sake of collecting data.

2.1 Information You Provide Directly

When you create an account, use our services, or communicate with us, you provide us with:

  • Full name — used to identify your account and process transactions
  • Mobile phone number — used for account verification, security alerts, and two-factor authentication
  • Email address — used for account communications, transaction confirmations, and security notifications
  • Password — stored in encrypted, hashed form; we never store or access your plain-text password
  • Referral code — if applicable, used to credit commission to the referring member
  • Payment account details — such as JazzCash or EasyPaisa account numbers, used solely to process deposits and withdrawals
  • Bank account information — where bank transfer is selected as a payment method
  • Identity verification documents — where required by applicable law or our compliance policies (such as CNIC or passport number for withdrawal verification above certain thresholds)
  • Communications with our support team — including messages, emails, and any attachments you send us

2.2 Information Collected Automatically

When you access the SunZee1 platform, our systems automatically collect certain technical information:

  • IP address — used for security monitoring, fraud detection, and geographic access controls
  • Device type and model — used to optimize platform performance for your device
  • Browser type and version — used to ensure compatibility
  • Operating system — used for technical support and performance optimization
  • Session timestamps — used to detect anomalous access patterns and unauthorized logins
  • Pages visited and features used — used in anonymized, aggregated form to improve the platform
  • Transaction logs — every deposit, withdrawal, investment, and earning credit is logged with timestamps for audit purposes

2.3 Information from Third Parties

In limited circumstances, we may receive information about you from third parties:

  • Payment processors — transaction confirmation data from JazzCash, EasyPaisa, and banking partners
  • Fraud detection services — risk signals used to protect your account from unauthorized activity
  • Regulatory bodies — in response to lawful requests from SECP, FBR, or other competent authorities

3. How We Use Your Information

We use the information we collect for the following specific purposes:

3.1 To Operate the Platform

  • Creating and managing your SunZee1 member account
  • Processing investment plans and calculating hourly profit distributions
  • Executing deposit and withdrawal transactions
  • Crediting referral commissions across all five program levels
  • Operating the auto-reinvest feature when activated

3.2 To Verify Your Identity and Prevent Fraud

  • Confirming your identity during account registration
  • Monitoring transactions for suspicious activity using our anomaly detection systems
  • Verifying withdrawal requests against your whitelisted accounts
  • Detecting and preventing unauthorized access attempts
  • Complying with anti-money laundering (AML) and know-your-customer (KYC) obligations

3.3 To Communicate With You

  • Sending transaction confirmations and account activity notifications
  • Delivering security alerts — such as new device logins or withdrawal requests
  • Responding to your customer support inquiries
  • Notifying you of material changes to our terms, policies, or platform features
  • Sending platform news and investment updates where you have opted in to receive these

3.4 To Improve the Platform

  • Analyzing anonymized, aggregated usage patterns to identify areas for improvement
  • Diagnosing and resolving technical issues
  • Testing new features before wide release
  • Responding to user feedback submitted through support channels

3.5 To Comply With Legal Obligations

  • Maintaining transaction records as required by Pakistani company and tax law
  • Responding to lawful requests from regulatory authorities including SECP and FBR
  • Meeting our obligations under applicable financial regulations

4. Legal Basis for Processing Your Data

We process your personal information on the following legal grounds:

  • Contract performance: Processing necessary to fulfill our obligations to you as a SunZee1 member — including operating your account, distributing profits, and processing transactions
  • Legal obligation: Processing required to comply with Pakistani law, SECP regulations, FBR tax requirements, and applicable AML/KYC rules
  • Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement — where these interests do not override your fundamental privacy rights
  • Consent: Where we rely on your consent — such as for optional marketing communications — you may withdraw that consent at any time without affecting any other processing

5. How We Share Your Information

We do not sell your personal information. We do not share it with advertisers. We share it only in the following limited, specific circumstances:

5.1 Service Providers

We share necessary information with trusted third-party service providers who assist us in operating the platform:

  • Payment processors — to execute deposits and withdrawals
  • Cloud infrastructure providers — to host platform data securely
  • Security and fraud detection services — to protect your account
  • Customer support tools — to manage and respond to your inquiries

All service providers are bound by contractual obligations to protect your data and use it only for the specific purposes for which it was shared.

5.2 Legal and Regulatory Authorities

We will disclose your information to government authorities, regulators, or law enforcement agencies when:

  • Required to do so by applicable Pakistani law or regulation
  • In response to a valid legal order, court order, or regulatory demand
  • Necessary to protect the rights, property, or safety of SunZee1, our members, or the public

We will notify you of such disclosures where we are legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of SunZee1’s business, your personal information may be transferred as part of that transaction. We will notify you in advance of any such transfer and explain your options.

5.4 With Your Explicit Consent

We may share your information with other parties in circumstances not described above if we have obtained your explicit, informed consent to do so.

6. Data Security

SunZee1 is ISO 27001 certified — the internationally recognized standard for information security management. Our security measures include:

  • End-to-end encryption for all data transmitted between your device and our servers
  • Hardware-backed authentication sessions to prevent session hijacking
  • Bcrypt password hashing — your password is never stored in readable form
  • Two-factor authentication (2FA) — optional but strongly recommended for all members
  • Withdrawal whitelisting — only pre-approved accounts can receive your withdrawals
  • Automated anomaly detection — every payout is screened for unusual patterns
  • On-chain settlement records — blockchain-based transaction logs that cannot be altered
  • Regular penetration testing — independent security audits conducted periodically
  • Strict internal access controls — only authorized personnel with a legitimate need can access member data

Despite these measures, no system is completely impenetrable. We encourage you to use a strong, unique password for your SunZee1 account and to enable two-factor authentication immediately after registration.

7. Data Retention

We retain your personal information for as long as:

  • Your account remains active on the platform
  • Necessary to fulfill the purposes described in this policy
  • Required by applicable Pakistani law and regulatory obligations

Specifically:

  • Account data is retained for the duration of your membership plus a minimum of five years following account closure, as required by financial record-keeping regulations
  • Transaction records are retained for a minimum of seven years in compliance with FBR and corporate law requirements
  • Support communications are retained for three years from the date of the most recent communication
  • Security logs are retained for two years for fraud investigation purposes

When retention periods expire, data is securely deleted or anonymized in accordance with our internal data destruction procedures.

8. Your Privacy Rights

As a SunZee1 member, you have the following rights regarding your personal information:

Right to Access

You may request a copy of all personal information we hold about you at any time.

Right to Correction

If any information we hold about you is inaccurate or incomplete, you may request that we correct it.

Right to Deletion

You may request deletion of your personal information where we no longer have a legal obligation to retain it. Please note that we are required by law to retain certain transaction and financial records for specified periods.

Right to Restrict Processing

You may request that we limit how we use your information in certain circumstances.

Right to Data Portability

You may request your personal data in a structured, commonly used, machine-readable format.

Right to Object

You may object to processing of your personal information where we rely on legitimate interests as our legal basis, and where your particular situation justifies an objection.

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 that occurred before withdrawal.

To exercise any of these rights, contact us at: privacy@sunzee-1.pk

We will respond to all legitimate requests within 30 days of receipt.

9. Cookies and Tracking Technologies

SunZee1 uses cookies and similar technologies to operate the platform securely and efficiently.

Essential Cookies

These cookies are strictly necessary for the platform to function. They maintain your login session, remember your security preferences, and enable core features. You cannot opt out of essential cookies without ceasing to use the platform.

Analytics Cookies

We use anonymized analytics to understand how members use the platform in aggregate. This data does not identify individual users and is used solely to improve platform performance.

Security Cookies

These cookies support our fraud detection and anomaly monitoring systems.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use core platform features.

10. Children’s Privacy

SunZee1 is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from anyone under 18 years of age. If we become aware that a member is under 18, we will immediately suspend the account and delete any associated personal data.

If you believe a minor has registered on our platform, please contact us immediately at privacy@sunzee-1.pk.

11. International Data Transfers

SunZee1 operates solar infrastructure and maintains operational affiliates across multiple countries. Your data may be processed or stored in jurisdictions outside Pakistan, including the United States through our US affiliate SunZee1 LLC. In all such cases, appropriate contractual safeguards are in place to ensure your data receives protection equivalent to Pakistani standards.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or platform features. When we make material changes, we will:

  • Update the “Last Updated” date at the top of this page
  • Notify you via email or in-app notification at least 14 days before the changes take effect
  • In cases of significant changes, request your renewed acknowledgment

Continued use of the platform after the effective date of changes constitutes acceptance of the updated policy.