pak789 Privacy Policy — How We Handle Your Data

This Privacy Policy ("Policy") is published by pak789 ("pak789", "we", "us", "our") and applies to all personal data collected, processed and stored in connection with the pak789 online gaming information platform, accessible at https://pak789.cam and all associated subdomains and mobile interfaces (collectively, the "Platform").

pak789 is committed to protecting the privacy and personal data of all users, including those accessing the Platform from cities across Pakistan such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. This Policy explains in plain English — with the level of detail required by applicable data-protection standards — exactly how we handle your information.

By registering an Account, accessing the Platform or submitting personal information through any part of our Services, you confirm that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not agree to any part of this Policy, you must discontinue use of the Platform.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, identification number, location data, online identifier or factors specific to the physical, economic, cultural or social identity of that person.
• "Processing" — any operation or set of operations performed on personal data, whether by automated means or otherwise, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure or destruction.
• "Data Controller" — pak789, which determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" — a third party that processes personal data on behalf of pak789 under a binding data-processing agreement.
• "Data Subject" — the individual to whom personal data relates — in this context, you, the user.
• "Consent" — any freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.
• "KYC" — Know Your Customer — identity and age verification procedures required for regulatory compliance.
• "AML" — Anti-Money Laundering — legislative and procedural requirements governing the prevention, detection and reporting of money laundering activities.
• "Cookie" — a small data file stored on your device by a website for the purposes of session management, functionality, analytics or marketing.

pak789 collects personal data in the following categories, depending on the nature of your interaction with the Platform:

3.1 Account Registration Data

When you create an Account, we collect the information you provide during the registration process, which may include:

• Full legal name;
• Date of birth (for age verification);
• Email address;
• Mobile telephone number;
• Residential address including city (e.g., Karachi, Lahore, Islamabad) and postal code;
• Preferred currency (e.g., PKR);
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with KYC and AML obligations, we may collect and process:

• Government-issued identity documents — typically a Pakistani CNIC (Computerised National Identity Card) or passport, including front and reverse images;
• Proof of address documentation (utility bill, bank statement or official letter dated within 3 months);
• Selfie or liveness check photograph or video;
• Additional documentation as may be required by applicable AML regulations.

3.3 Financial Transaction Data

When you make a deposit or withdrawal, we process transaction-related data including:

• Payment method identifier (e.g., masked account number, mobile wallet reference);
• Transaction amounts in PKR or other applicable currency;
• Transaction timestamps, reference numbers and processing status.

3.4 Usage and Technical Data

When you access the Platform, we automatically collect certain technical data:

pak789 collects personal data through the following channels:

• Directly from you — when you register an Account, complete KYC, make a deposit, contact support, respond to a survey or update your Account settings;
• Automatically — through cookies, server logs, device-fingerprinting tools and analytics software when you interact with the Platform;
• From third-party processors — identity verification providers, payment-processing partners and fraud-prevention services may share verification outcomes and transaction data with us in connection with your Account;
• From publicly available sources — in limited circumstances, for AML compliance, we may cross-reference publicly available sanctions lists or regulatory databases.

pak789 processes your personal data for the following specific purposes:

• Account Management: To create, operate, maintain and close your Account;
• Identity and Age Verification: To verify that you are who you say you are, that you meet the minimum age requirement (18+, or higher as required by the licence jurisdiction), and that your Account credentials match your identity documentation;
• Transaction Processing: To process deposits, withdrawals and any associated currency conversions;
• Regulatory Compliance: To fulfil KYC, AML and other applicable regulatory obligations, including responding to lawful requests from competent authorities;
• Fraud Prevention and Security: To detect, investigate and prevent fraudulent activity, collusion, money laundering, account takeovers and other security threats;
• Customer Support: To respond to your inquiries, resolve disputes and provide ongoing support;
• Responsible Gambling: To monitor gambling patterns for signs of problem gambling behaviour, to apply responsible gambling tools and to act on self-exclusion or limit requests;
• Platform Improvement: To analyse usage patterns, troubleshoot technical issues and improve the performance and functionality of the Platform;
• Legal Claims: To establish, exercise or defend legal claims in connection with the Platform or your Account.

pak789 processes your personal data on the following legal bases, applied on a purpose-by-purpose basis:

• Contract Performance — processing necessary to operate your Account and deliver the Services you have requested;
• Legal Obligation — processing required to comply with KYC, AML, sanctions screening and other applicable regulatory obligations;
• Legitimate Interests — processing necessary for fraud prevention, platform security, responsible gambling monitoring and legal-claim defence, where our interests are not overridden by your fundamental rights;
• Consent — where we rely on consent (for example, for optional marketing communications), you may withdraw that consent at any time by contacting our support team. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

pak789 does not sell your personal data. We share personal data with third parties only in the following limited and controlled circumstances:

• Identity Verification Providers: Third-party KYC and document-verification processors that authenticate your identity documents and perform liveness checks on our behalf;
• Payment Processors: Entities that facilitate deposit and withdrawal transactions — they receive only the data necessary to process the specific transaction;
• Fraud & AML Detection Services: Providers of fraud-scoring, risk-assessment and sanctions-screening tools used to protect the integrity of the Platform;
• IT Infrastructure Providers: Cloud-hosting, database and cybersecurity service providers that store and protect Platform data under binding data-processing agreements;
• Legal and Regulatory Authorities: Where we are required by law, court order, regulatory direction or lawful authority to disclose personal data — this may include disclosure to financial-intelligence authorities in connection with AML obligations;
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party data processors engaged by pak789 are bound by written data-processing agreements that prohibit the use of your data for any purpose other than the contracted service, and that require implementation of appropriate security measures.

pak789 operates internationally, and your personal data may be stored or processed in countries outside Pakistan. Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection to that applicable in the originating jurisdiction, pak789 will implement appropriate safeguards, which may include:

• Contractual data-transfer clauses binding the receiving party to equivalent data-protection standards;
• Binding corporate rules where data is transferred within a corporate group;
• Explicit consent, where no other transfer mechanism is available and you have been informed of the associated risks.

pak789 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. General retention guidelines are as follows:

• Account Data: Retained for the duration of the Account relationship and for a period of up to five (5) years following Account closure, or longer where required by regulatory or legal obligation;
• KYC / Identity Documents: Retained for the period required by applicable AML legislation following the end of the customer relationship — typically five (5) years;
• Transaction Records: Retained for a minimum of five (5) years in compliance with AML record-keeping obligations;
• Customer Support Records: Retained for up to three (3) years following resolution of the relevant inquiry or dispute;
• Technical / Usage Logs: Retained for up to twelve (12) months, except where extended retention is required for security investigation or legal proceedings.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where anonymisation is applied, the resulting data may be retained indefinitely for aggregate analytics purposes without restriction.

pak789 uses cookies and similar tracking technologies (including local storage and session tokens) to operate and improve the Platform. The categories of cookies we deploy are as follows:

pak789 does not deploy third-party advertising cookies or cookies that track your browsing activity across unrelated websites. You may manage or disable cookies through your browser settings at any time. Disabling strictly necessary cookies may impair the functionality of the Platform, including login and session management.

pak789 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, disclosure or destruction. These measures include:

• Transport Layer Security (TLS 1.2+): All data transmitted between your device and the Platform is encrypted in transit;
• Encryption at Rest: Sensitive stored data, including identity documents and financial records, is encrypted using industry-standard algorithms;
• Access Controls: Access to personal data is restricted on a need-to-know basis. Staff authorised to access personal data receive data-protection training and are bound by confidentiality obligations;
• Two-Factor Authentication: Available for user accounts to provide an additional layer of credential security;
• Intrusion Detection: Continuous monitoring systems are in place to detect and respond to potential security incidents;
• Penetration Testing: Regular security assessments are conducted to identify and remediate vulnerabilities.

Subject to applicable law, you hold the following rights in relation to the personal data pak789 holds about you. These rights can be exercised by contacting our support team using the details in Section 17.

We aim to acknowledge data-rights requests within 72 hours and to provide a substantive response within 30 calendar days. Complex requests may require additional time — you will be notified if an extension is necessary.

The pak789 Platform is strictly intended for adults aged 18 years and above, or the higher minimum age required by the applicable licence jurisdiction. We do not knowingly collect or process personal data from individuals below the minimum age requirement.

If we become aware that an Account has been registered by or on behalf of a person below the minimum age, we will immediately suspend the Account, forfeit any associated balance, and delete all personal data associated with the Account to the extent permitted by our legal obligations.

If you believe that a minor has registered an Account on pak789 or that their data has been submitted to our Platform, please contact our support team immediately using the contact details in Section 17. We will investigate and take appropriate action without undue delay.

pak789 serves a significant user base accessing the Platform from Pakistan, including users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other cities. We recognise that Pakistani data-protection law is evolving, and we are committed to applying data-handling practices consistent with the principles of applicable international standards.

No Disclosure to Pakistani Regulatory Bodies Without Legal Basis: pak789 does not proactively share user data with the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any Pakistani provincial authority, except where required to do so by a valid and lawful legal order addressed to us. We will challenge any request for user data that we consider to be unlawful, overbroad or disproportionate.

Payment Provider Data: Where you transact using Pakistan-based payment references such as Easypaisa, JazzCash or Raast, the relevant provider processes your transaction data under its own privacy policy. pak789 does not control how payment providers process your data on their side of the transaction. We recommend reviewing the privacy policy of any payment provider before initiating a transaction.

The pak789 Platform may reference or describe third-party services — including payment providers, game developers and sports data sources — for informational and educational purposes. Where the Platform contains links to or descriptions of third-party websites or services, pak789 is not responsible for the privacy practices or data-processing activities of those third parties.

We strongly encourage you to review the privacy policies of any third-party service you choose to access or use in connection with online gaming activity. pak789's Privacy Policy applies solely to data processed through the pak789 Platform itself.

pak789 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or the structure of our Services. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page;
• Notify registered users via email or a prominent in-Platform notice for material changes;
• Where required by applicable law, seek fresh consent for any new processing activities that affect previously collected data.

Your continued use of the Platform following the publication of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not agree to a material change, you may request Account closure in accordance with the Terms and Conditions.

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the pak789 Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Privacy Request — [Your Account Username]" for data-rights requests to ensure prompt routing;
• Live Chat: 24/7 via the chat widget on the Platform;
• Response Languages: English (primary); Urdu available on request;
• Acknowledgement: Within 72 hours of receipt;
• Substantive Response: Within 30 calendar days (extensions possible for complex requests with prior notification).