So basically, it looks like the main object is to hope to get over 12, because that gets you T3h Golden Zero. You can see where the blatant house edges are: 7-7 tie (7 being the most common two-card hand) surrendering, and the dealer taking a card on any 9, 10 or 11. Interesting though that the house doesn't necessarily take a card on 12...
Basically, like Chris said, it's Blackjack meets Baccarat, and not in a good way. At least in Baccarat, the opportunity for a win is always there. In this game, just like Blackjack, it's quite possible for a hand to occur where a player has no way to win, no matter how they play it.
Pass.