Privacy Policy

1 Introduction

By registering an account, accessing the Platform or otherwise providing us with your personal data, you acknowledge that you have read and understood this Policy and consent to the data practices described herein to the extent that consent is the applicable legal basis for processing.

This Policy applies to all users of the 789com Platform, including users accessing the site from cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar, as well as users in other locations worldwide. Where applicable law requires specific additional disclosures, those are addressed in the jurisdiction-specific section of this Policy.

789com does not hold a Pakistan gambling licence and does not claim to be regulated by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA) or the State Bank of Pakistan. This Policy is published as a matter of transparency and does not constitute legal advice. Pakistani users are solely responsible for understanding and complying with applicable local laws, including those pertaining to data protection.

2 Definitions

The following definitions apply throughout this Policy:

• "Personal Data" — any information that identifies or can reasonably be used to identify a living individual, either directly or in combination with other data.
• "Processing" — any operation performed on personal data, including collection, recording, storage, alteration, retrieval, consultation, use, disclosure, restriction or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing personal data; in this context, 789com.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller, under a data processing agreement.
• "KYC" — Know Your Customer; the identity and age verification process required before certain account functions are available.
• "AML" — Anti-Money Laundering; the regulatory and compliance framework relating to the prevention of financial crime.
• "Cookie" — a small text file placed on your device by the Platform to enable certain website functions and analytical capabilities.
• "Account" — the personal registered account held by a user on 789com.

3 Data We Collect

789com collects personal data in the following categories, depending on the nature of your interaction with the Platform:

3.1 Registration Data

• Full legal name;
• Date of birth;
• Email address;
• Residential address;
• Mobile phone number;
• Username and password (stored in hashed, non-reversible form).

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (Pakistani CNIC or passport);
• Proof of address documentation (utility bill, bank statement or equivalent);
• Selfie photographs or liveness-check video for biometric matching purposes;
• Payment method ownership documentation where source-of-funds verification is required.

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, methods and processing status;
• Payment method identifiers (e.g., partial mobile wallet numbers for Easypaisa or JazzCash, bank account reference numbers for HBL, UBL, Meezan Bank or Bank Alfalah) — these are retained solely to verify source-of-funds ownership and to process refunds where applicable;
• Account balance history and transaction records.

3.4 Activity & Behavioural Data

• Betting and gaming history, including wager amounts, selections, odds and outcomes;
• Session duration, login timestamps and platform navigation patterns;
• Responsible gambling tool usage and settings.

3.5 Technical & Device Data

• IP address and approximate geographic location derived from IP;
• Device type, operating system and browser version;
• Cookie identifiers and session tokens.

3.6 Communications Data

• Records of support interactions via Live Chat, Help Center and email;
• Correspondence relating to disputes, complaints or account queries.

4 Legal Basis for Processing

Where data protection law requires that processing of personal data be grounded in a lawful basis, 789com relies on the following:

5 How We Use Your Data

789com processes personal data for the following purposes:

• Account operation — to create, maintain and authenticate your account, including password resets and security alerts;
• Identity and age verification — to confirm that you meet the minimum age requirement (18+ or the higher minimum required by the operator/licence jurisdiction) and that registration details are accurate;
• Payment processing — to facilitate deposits, withdrawals and refunds, and to verify the ownership of payment instruments used;
• Fraud prevention and AML compliance — to detect and investigate suspicious activity, multiple-account registrations and potential financial crime;
• Customer support — to respond to enquiries, resolve disputes and assist with account issues via Live Chat, Help Center and email;
• Responsible gambling — to monitor account activity for signs of problematic gambling behaviour and to administer self-exclusion and limit-setting tools;
• Service improvement — to analyse platform usage patterns and technical performance in order to improve user experience;
• Legal compliance — to fulfil reporting or data-retention obligations required by applicable law.

We do not use personal data to build profiles for sale to third-party advertisers, nor do we use it for any purpose materially different from those listed above without first providing you with notice and, where required, obtaining your consent.

6 Data Sharing & Disclosure

789com does not sell personal data to third parties. We may share data in the following limited circumstances:

• KYC and identity verification partners — third-party verification services that process identity documents and perform liveness checks on our behalf under data processing agreements;
• Payment processors — to facilitate deposits and withdrawals, we share transaction-relevant data (not full credentials) with the applicable payment infrastructure providers;
• Fraud and AML partners — we may share data with specialist fraud detection and financial crime prevention services to protect the integrity of the Platform;
• Legal authorities — we will disclose personal data to law enforcement, regulatory bodies or courts where required to do so by applicable law, a valid legal order or to protect the rights and safety of users and the Platform;
• Corporate transactions — in the event of a merger, acquisition or sale of all or part of the business, personal data may be transferred to the acquiring entity, subject to equivalent privacy commitments.

All third-party Data Processors engaged by 789com are contractually bound to process personal data only as instructed, to maintain appropriate security standards and to not disclose data to further parties without authorisation.

7 Data Retention

Personal data is retained for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory and operational requirements. In practice:

• Active account data — retained for the full duration of the account relationship plus the minimum period required under applicable law after account closure;
• KYC and identity documents — retained for a minimum of five (5) years from the date of account closure, or longer where required by AML or applicable regulatory obligations;
• Financial transaction records — retained for a minimum of five (5) years from the date of the transaction, in accordance with standard financial record-keeping requirements;
• Support communications — retained for up to three (3) years from the date of the last interaction, or longer where related to an unresolved dispute or legal proceeding;
• Marketing consent records — retained for the duration of the consent and for a reasonable period thereafter for audit purposes.

Where data is no longer required for any lawful purpose, it is securely deleted or anonymised in a manner that prevents re-identification.

8 Data Security

789com implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration or destruction. These measures include:

• HTTPS/TLS encryption — all data transmitted between your device and 789com servers is encrypted in transit;
• Password hashing — account passwords are stored using strong one-way hashing algorithms and are not readable in plain text by Platform staff;
• Access controls — personal data access is restricted to authorised personnel with a legitimate need-to-know, governed by role-based access controls;
• Secure document handling — KYC documents are submitted via dedicated HTTPS-secured verification portals and are not processed through unsecured channels;
• Incident response — 789com maintains procedures for identifying, assessing and responding to data security incidents, including notification obligations where required by applicable law.

9 Cookies & Tracking Technologies

789com uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are described below:

You may manage cookie preferences through your browser settings. Disabling essential cookies may impair Platform functionality, including login and account access. Disabling analytical cookies will not affect your ability to use the Platform but will limit our ability to improve the service.

789com does not use cookies to serve targeted third-party advertising or to build cross-site user profiles for resale.

10 International Data Transfers

789com may transfer personal data to countries outside your country of residence in connection with the operation of the Platform, including to KYC partners, payment processors and technical infrastructure providers. Where such transfers occur, 789com ensures that appropriate safeguards are in place, which may include:

• Adequacy decisions recognising the destination country's level of data protection;
• Standard contractual clauses or equivalent contractual protections with the recipient entity;
• Binding corporate rules where the transfer is intra-group.

Pakistani data protection law is currently evolving. Users in Pakistan should be aware that data submitted to 789com may be processed and stored in jurisdictions outside Pakistan and that the level of data protection in those jurisdictions may differ from Pakistani standards. By using the Platform, you acknowledge this international processing context.

11 Minors & Age Verification

Age verification is a mandatory step in the KYC process. All users are required to confirm their date of birth at registration and to submit identity documentation proving they are of the required minimum age before withdrawal functionality is enabled. If you believe a minor has created an account on the Platform, please contact the support team immediately via Live Chat or the Help Center.

12 Your Data Rights

Subject to applicable law, you may have the following rights in relation to your personal data held by 789com. To exercise any of these rights, please contact us through the support channels described in Section 15.

789com will respond to rights requests within a reasonable timeframe in accordance with applicable law. We reserve the right to request identity verification before processing any data rights request to prevent unauthorised access to personal data.

13 Notes for Pakistani Users

Pakistan is in the process of developing a comprehensive data protection legislative framework. At the time of writing, a Personal Data Protection Bill has been under consideration. Pakistani users should be aware that:

• 789com does not operate under Pakistani data protection law as a regulated entity in Pakistan and does not claim authorisation from Pakistani data protection authorities;
• Personal data submitted by Pakistani users may be processed and stored in servers located outside Pakistan;
• The legal remedies available to Pakistani users for data protection grievances are subject to the evolving legislative landscape in Pakistan;
• Users in Pakistan may contact 789com's support team to raise any data-related concern — all requests will be handled in good faith regardless of jurisdictional limitations.

References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah in connection with payment processing are provided as contextual references only. Transaction data shared with payment infrastructure providers is limited to what is technically necessary to process the transaction and does not include full account credentials. None of these providers endorses gambling or this operator.

14 Policy Amendments

789com reserves the right to update or amend this Privacy Policy at any time. Material changes — for example, changes that affect how we share data with third parties or that introduce new data collection categories — will be communicated to registered users via the Platform or by email to the address on file.

The "Last Updated" date at the top of this page always reflects the current version. We encourage users to review this Policy periodically. Continued use of the Platform following notification of changes constitutes acceptance of the revised Policy.

15 Contact Us

If you have any questions about this Privacy Policy, wish to exercise a data right, or have a concern about how your personal data has been handled, please contact the 789com Data Support team:

789com does not operate a telephone support line for data protection enquiries. Please use the email or Live Chat channels above. We aim to acknowledge all data-related enquiries within five (5) business days and to resolve them within thirty (30) days, subject to the complexity of the request.